TO: Animal Welfare Policy
Ministry for Primary Industries
PO Box 2526
Wellington 6140
FROM: The Soil & Health Association
PO Box 340002
Birkenhead
Auckland 0746
Phone: 0212667754
Email: advocacy@organicnz.org.nz
Website: www.organicnz.org.nz
Submission on Animal Welfare Regulations by the Soil & Health Association
Introduction
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.
Soil & Health recognises that New Zealand animal welfare standards need improving. Every year thousands of animals in New Zealand are farmed intensively, fed high doses of antibiotics, and grains with herbicide residues, kept in unhygienic and cramped conditions, with high levels of stress and injury, unable to express normal behaviours, which runs contrary to the stated principles in the Animal Welfare Act 1999.
As an organic organisation we advocate for the highest animal welfare standards. Organic livestock farming is based on the harmonious relationship between land, plants and livestock, respect for the physiological and behavioural needs of livestock and the feeding of good-quality organically grown feedstuffs. We support the Five Freedoms as set out under the Animal Welfare Act 1999. We believe that any farming methods that cause animals to suffer or prevent them from expressing normal patterns of behavior should be phased out. This is why we welcome the opportunity to comment on the Proposed Animal Welfare Regulations discussion document (the document), which contains the Government’s proposals to improve the enforceability, clarity and transparency of the animal welfare system in New Zealand.
The current animal welfare system does not deal properly with lower-level offending. Soil & Health supports the majority of the proposed regulations in the document in general as they enable the Ministry for Primary Industries to better enforce compliance with the Animal Welfare Act 1999. These include proposals for increasing penalties and infringement fees for offences. However Soil & Health has concerns with some of the proposed regulations and believe that a number of cruel practices outlined, such as colony cages and farrowing crates, should be phased out and prohibited altogether.
Detailed submissions
10. – Care and Conduct Regulatory Proposals
All Animals
1. Electric prodders
Soil & Health supports the proposed regulation in part. Electric prodders are a cruel device. We oppose the exceptions of their use for cattle over 100kg, at a commercial slaughter premise, and for a circus. We believe that alternatives should be found for the intention of moving animals and that electric prodders should only be used when the safety of the handler is at risk. We believe that restrictions should be placed on the possession and sale of electric prodders, as these devices are freely available and sold online with no requirement for information or training to be provided to purchasers. We do however support the proposal being placed in regulation as it means it will be directly enforceable.
2. Use of goads
Soil & Health supports the proposed regulation to prohibit the use of goads to prod an animal in the udder, anus, vulva, scrotum or eyes. The use of goads to move animals causes the animals to become nervous and fearful. The use of electric goads and physical goads such as sticks will obviously cause pain. We support placing the prohibition in regulation as it means it will be directly enforceable.
3. Twisting an animal’s tail
Soil & Health strongly supports the proposed regulation to prohibit twisting the tail of an animal in a manner that causes the animal pain. Tail twisting is an unnecessary and cruel practice often used to restrain and move animals and can risk leading to tail breaking, which causes pain and distress. We support the regulation as it provides an enforceable deterrent to tail twisting.
Goats
13. Tethered goats
While Soil & Health does not support the tethering of goats generally, as they are naturally foraging herd animals and tethering them prevents them from expressing their natural instincts to roam and forage freely, we do support the minimum requirement of constant access to food, water and shelter if tethered. However we believe that the word ‘shelter’ needs to be further defined. Shelter must be defined as providing a space that is clean, dry and has adequate space. As stated in the document, goats are more susceptible to hypothermia than sheep therefore the definition of shelter must also include providing protection from the natural elements including wind and rain, and weather extremes such as snow and hail.
Layer hens
17. Opportunity to express normal behaviours in housing systems
Soil & Health supports the new requirements under 17(a) that hens must have the opportunity to express a range of natural behaviours, becoming part of regulation and thereby becoming directly enforceable.
18. Stocking densities
While Soil & Health supports the proposed stocking regulations becoming part of regulation, thereby making them directly enforceable, we are strongly opposed to the specific stocking densities set out under 18. We believe that stocking hens at this density will not allow them the opportunity to express the range of natural behaviours outlined under 17(a). We believe that for hens to express the range of natural behaviours outlined under 17(a) they must be stocked at 6 birds per m2, with a minimum of 18 cm perch space provided for each bird.
19. Housing and equipment design
While Soil & Health supports the housing and design regulations becoming part of regulation thereby making them directly enforceable, we are strongly opposed to the use of closed cages including colony cages for all poultry, not just laying hens. Closed cages do not allow the animals the opportunity to express the range of natural behaviours outlined under 17(a). Chickens are biologically omnivores and instinctively, when given the opportunity, actively forage for green growing plants, animal foods such as earthworms and insects, wild fruits and some seeds.We therefore believe that if we are going to allow hens the ability to express the range of natural behaviours outlined under 17(a) they must have unrestricted access to outside runs, with at least 50% of the outside run area covered with vegetation at all times, allowing the hens constant access to fresh grass or forage crop containing a diversity of species. We believe that all poultry sheds should have access to good pasture, and be situated to allow for rotation of grazing areas – for example mobile poultry sheds. We believe that adequate nesting space should be provided at a minimum of 7 birds per nest, and that perchesshould be available in all laying hen housing to a minimum of 18cm perch space per bird.
Pigs
24. Dry sleeping area
Soil & Health supports the proposal that pigs must have access to a dry sleeping area. Failure to provide a dry sleeping area can cause distress and ill health, particularly when a sow is pregnant and is trying to create a nest for her piglets. Furthermore pigs have clean toilet habits and in nature would never defecate near where they sleep. However if left in a confined area then pigs may be left to lie in their own excrement. Providing a dry sleeping area means this would not happen.
25. Lying space for grower pigs
Soil & Health strongly oppose the proposed lying space for grower pigs. We do not believe the proposed spacing will allow for improvement of overstocking behaviour issues such as aggression, nor allow for the pigs to express normal behaviours. Keeping pigs at this density does not allow them to roam, play or dig as they would naturally outdoors. We believe that all pigs should have access to outdoor pasture.
26. Dry sow stalls
Soil & Health strongly supports the prohibition of dry sow stalls and placing the prohibition in regulation thereby making it directly enforceable. Dry sow stalls are an inhumane and cruel practice. Pigs are highly intelligent, social animals. Keeping sows in individual stalls deprives them of their most basic needs such as fresh air, sunlight, clean water and soft bedding, as well as their need to socialise. We support this proposal as it places prohibition in regulation, making it directly enforceable.
27. Size of farrowing crates
Soil & Health supports the proposal as it places prohibition in regulation, thereby making it directly enforceable, however we strongly oppose the use of farrowing crates in general and believe that they should be banned altogether. Farrowing crates only allow the sow to either stand up or lie down, thereby preventing her to properly mother her piglets. This causes frustration and depression and is therefore an inhumane and cruel practice that we do not support.
28. Provision of nesting material
Soil & Health supports the use of nesting material in the farrowing system. As stated sows have a strong behavioural instinct to build a nest prior to farrowing. With no material for bedding she would scrape her nose over the bare concrete in an attempt to build a nest for her piglets. Not providing materials that the sow can manipulate prevents her from expressing natural behaviours. We therefore support this proposal as it means that any offences of not providing nesting material for sows will be directly enforceable. We however propose that the wording be changed to state “natural material”, which should be further defined with a list of specific natural materials to be used such as straw, twigs and grasses. We further propose that the nesting material be a mandatory requirement all the way through farrowing until after the piglets have been raised and weaned.
Cattle
31. Milk stimulation
Soil & Health were not aware of this practice still occurring however believe it is unnecessary and cruel. We support the proposal to prohibit stimulating milk let-down by inserting water or air into a cow’s vagina, and placing it in regulation thereby making it directly enforceable. We believe that it warrants regulation so that effective action can be taken if it occurs.
32. Cattle and sheep – vehicular traction in calving or lambing
Soil & Health supports this proposal to prohibit using a moving vehicle to provide tractions in calving or lambing, making it part of regulation thereby making it directly enforceable. We believe it is an unnecessary and unnatural technique that has a high risk of causing injury, pain and distress to both the young and the mother. We support animals birthing naturally without artificial stimulation and force. We believe that it warrants regulation so that effective action can be taken if it occurs.
11.0 Young calf management regulatory proposals
43. Loading and unloading facilities
Soil & Health supports the proposed regulation that facilities must be provided to enable young calves to walk onto and off transportation by their own action. However we believe that the regulation needs to specify acceptable methods of loading and unloading, for example stating that they must be ramps, or electronic lifts. We do not believe that the regulations should allow for flexibility for other methods that would enable calves to walk onto and off vehicles, as this may allow for breaches of welfare. We believe all acceptable methods should be specifically stated to provide for full clarity. Further we believe that the time period to allow farmers and other businesses to make arrangements necessary to put suitable loading and/or unloading facilities in place should not be more than 12 months.
44. Shelter on-farm, before and during transportation and at processing plants
Soil & Health supports the proposed regulation in part. We believe that the regulation on shelter should also cover the stocking density of animals in pens. Stocking density should be at a rate that provides enough room for all calves to lie down.
45. Fitness for transport – age
Soil & Health opposes the proposed regulation that young calves must not be transported for processing and slaughter until they are at least four days of age. We believe four days old is an unacceptable age, being too young for travel. As stated in the document the four-day minimum age is not a guarantee that individual calves will be in a suitable physical condition for transportation. While the intention is for the regulation to be read together with those regulations for the physical condition of young calves we do not believe this will happen in practice, and it will also make it more difficult to enforce. We propose that the age be lifted to match that of the European Union of 10 days old, rising to 14 days old for longer journeys over eight hours. Raising the age to 10-14 days means that there is a strongly likelihood that the young calf will be in a suitable physical condition for transportation.
46. Fitness for transport – physical characteristics
Soil & Health supports this proposed regulation. However as stated above we believe by raising the minimum age for transportation to 10-14 days old that this will help to ensure that the young calves are in suitable physical condition for transportation.
47. Maximum time off feed
Soil & Health supports this proposed regulation to reduce the amount of hours off feed from 30 to 24 however we believe that 24 hours is still too long to go without feed for young calves. Naturally a young calf would feed from their mother every 2 to 3 hours. Calves began to feel hunger soon after 3 hours from their last feed, when plasma glucose begins to decline. Hunger then increases gradually for the next 15 hours and then rapidly over the final 12 hours. Leaving young calves without feed for such a long duration is cruel, and also leaves them physically weak. We believe that 24 hours is an unreasonable maximum period to permit young calves to be off feed when being transported prior to slaughter. We propose that the time period be reduced below 24 hours.
48. Duration of transport
Soil & Health supports the proposed regulation to reduce the maximum amount of time a young calf spends in transportation from 12 hours to 8 hours.
49. Blunt force trauma
Soil & Health supports the proposed regulation to prohibit the use of blunt force trauma for killing calves.
50. Transport by sea across Cook Strait prohibited
Soil & Health supports the proposed regulation to prohibit the transportation by sea of young calves across the Cook Strait. We believe that the infringement fee of $500 rather than $300 is a suitable penalty.
12.0 Surgical and painful procedures regulatory proposal
66. Cattle – tail docking
Soil & Health supports the proposed regulation to prohibit tail docking of cattle. We believe it is a cruel and unnecessary procedure especially when there are other alternatives such as switch trimming. Tail docking can lead to significant health problems, including incontinence, hernias, phantom tail pain and increased sensitivity to pain. Further more tail docking does not improve cow hygiene. Tail docking on cattle is a purely anthropocentric procedure that improves comfort for milking personnel only. We support the proposed restrictions that tail docking only is performed for therapeutic purposes (i.e. in response to disease or injury), that a veterinarian or a veterinary student under the direct supervision of a veterinarian must perform it, and that pain relief must be used at the time of procedure.
67. Cattle and sheep – castration and shortening of the scrotum
Soil & Health supports this proposal in part. We propose that castration and shortening of the scrotum only be permitted at a young age of less than 6 months. Castration beyond 6 months of age should be banned. We support the proposed regulation that only conventional rubber rings must be used for this procedure as it helps to minimise the level of pain and distress an animal experiences. We also support the use of pain relief at the time of the procedure.
69. Cattle, sheep, & goats – dehorning
Soil & Health supports this proposal in part. We propose that dehorning only be permitted in the budding stage. Dehorning is a painful procedure. Studies have shown that dehorning stimulates both an acute pain response and a delayed inflammatory reaction. Young animals tend to recover quicker and have fewer complications than animals dehorned at an older age. It is generally accepted that the younger the animal, the less painful the procedure. We do however support the proposal to make pain relief mandatory at the time of the procedure.
70. Sheep – tail docking
Soil & Health supports this proposal in part. We propose that tail docking be banned on sheep i.e. over 12 months of age. We understand that tail docking of sheep has benefits such as reducing problems like fly strike. However tail docking is a painful procedure so restricting it to lambs will result in less pain and therefore reduce the impact of the procedure on the animal. We support the rest of the proposals for tail docking under 6 months of age and tail docking over 6 months of age and believe it provides a clear mandatory standard for the procedure. However we believe that the tail length should be further specified as the current wording “must not be cut flush” is unclear and confusing.
71. Sheep – mulesing
Soil & Health strongly supports the proposal to prohibit mulesing of sheep and placing this prohibition in regulation, thereby making it directly enforceable. This procedure is one of the most barbaric and cruel practices carried out in the farming industry. It is an extremely painful practice and lambs have been seen to demonstrate abnormal behaviour indicative of extreme pain for days afterwards. We believe that the most humane alternative to sheep mulesing is to breed sheep to have low wrinkles, fewer dags and less wool around their breech, and that this should be a stated objective. Other effective alternatives are tailing docking of lambs, timing of shearing and crutching, effective natural control of scouring (especially the control of intestinal worms), strategic application of natural treatments to prevent flystrike, and regular inspection of the flock especially daily during high risk periods.
72. Deer – develvetting
Soil & Health opposes this proposal, as we believe that the develvetting of deer should be prohibited. However if it is to go ahead we do not believe that farmers should undertake this procedure themselves, even if given veterinary approval. It should be made mandatory that only a vet or veterinary student under direct veterinarian supervision should undertake this procedure.
74. Horses – tail docking
Soil & Health supports the proposed regulation to prohibit tail docking of horses. We believe it is a cruel and unnecessary procedure. We support the proposed restrictions that tail docking only is performed for therapeutic purposes (i.e. in response to disease or injury), that a veterinarian or a veterinary student under the direct supervision of a veterinarian must perform it, and that pain relief must be used at the time of procedure.
80. Pigs – castration
Soil & Health supports this proposal in part. We propose that castration of pigs only be permitted at a young age of less than 6 months. Castration beyond 6 months of age should be banned. We support the proposed regulation that a veterinarian or a veterinary student under the direct supervision of a veterinarian must perform the procedure, and that pain relief must be used at the time of procedure.
81. Pigs – tail docking
Soil & Health opposes the regulation to allow for tail docking of pigs. We believe it is a cruel and unnecessary practice. The reason tail docking of pigs is performed is to reduce the incidence of tail biting. However tail biting is a result of keeping pigs in high-density stocking numbers and pigs become frustrated and distressed. Pigs are highly intelligent, inquisitive animals and need intellectual stimulation such as natural material to play with. Studies have shown that providing straw or other manipulable materials and keeping a lower density of pigs in a pen could largely prevent tail biting.
Conclusion
As set out above, Soil & Health supports the majority of the proposed regulations in in the document in general, however we oppose a number of the proposed regulations as they either prevent animals from expressing normal patterns of behaviour, or they are cruel mutilation practices that cause harm and distress, thereby running contrary to the Animal Welfare Act. We believe that animals should not be kept in closed cages. Instead all animals should have unrestricted daily access to pasture. We therefore strongly oppose the use of colony cages for poultry and farrowing crates for pigs and believe they should be prohibited. In summary, while we commend the government for their efforts to tighten animal welfare regulation and create better enforcement with the Animal Welfare Act, we believe there is still much room for improving New Zealand’s animal welfare standards to better meet the physiological and behavioural needs of animals.
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
Councils and communities – a collaborative response to GE risks
/in GE, GM, Media ReleasesWhangarei and Far North District Councils received strong support from the community for their proposals to protect their territories from GM releases this week.
The Soil & Health Association of NZ and GE Free Northland led a group of 14 submitters, presenting their case at a joint hearing on Whangarei District Council and Far North District Council’s proposed district plan changes for the outdoor use of genetically modified organisms (GMOs).
Soil & Health and GE Free Northland engaged independent expert witnesses to outline the case for the precautionary approach to GMO releases that both councils have proposed for their District Plans.
“Soil & Health has concerns about potential adverse impacts of GMO activities on the ability of the organic sector, tangata whenua and the community to provide for their social, environmental, economic and cultural well-being,” said Marion Thomson, co-chair of Soil & Health. “The proposed District Plan changes provide practical, commonsense ways of protecting communities.”
The plan changes would allow veterinary vaccines that use GMOs to be used without permits, but outdoor field trials would require council consent. Releasing GMOs to the environment would be prohibited for the life of the plans,or until such time as there is certainty as to how any risks can be managed.
Discretionary activities (outdoor field trials) would need to meet certain standards, including bonds to cover the costs of any unintended economic, health or environmental damage caused by EPA-approved GE experiments and the costs of ongoing monitoring.
“Government agencies have a poor track record in containing outdoor GE experiments, and the law has very limited liability provisions for damage,” said Zelka Grammer, chairperson of GE Free Northland. “The local community supports a precautionary approach to outdoor GE experiments, strict liability provisions imposed by local councils, and an outright ban on the release of GMOs in their patch, due to the serious risks to our biosecurity, unique biodiversity and environment.”
Many members of GE Free Northland are primary producers whose livelihood is from farming, horticulture, forestry and beekeeping, or home gardeners, all of whom could be adversely affected by GMOs.
There is no scientific consensus as to the potential effects of GMOs on the environment. Irrespective of the threat GMOs pose to the environment, GMO contamination risks significant adverse effects on social, economic and cultural values.
Soil & Health and GE Free Northland strongly support the right of communities to decide whether or not GMOs are released or field-trialled in their regions and, if so, whether any conditions should be placed on them. This was confirmed by the landmark Environment Court decision in 2015 that councils have the power under the Resource Management Act to control the use of GMOs in their regions.
Media contacts
Marion Thomson
Co-chair, Soil & Health
027 555 4014
Zelka Grammer
Chairperson, GE Free Northland
022 309 5039
Marty Robinson
Spokesman, GE Free Northland
09 407 8650
022 136 9619
Next steps for fresh water
/in Submissions‘Next Steps for fresh water’ consultation document
Submission by the Soil & Health Association
Introduction
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.
Soil & Health recognises that New Zealand freshwater is in a dire state, with a staggering 62% of monitored waterways being unsafe for swimming. A big factor in this is nitrogen pollution from the increasing intensification of agriculture. Nitrogen pollution is mainly from cow urine diffusing through soils and pasture root zones, so simply planting stream banks and fencing off streams cannot solve this issue. Going organic is part of the solution to fixing polluted fresh waterways in New Zealand. Organic dairy farming involves no soluble nitrogen fertilisers, lower stock numbers, more biodiversity, and grass-fed cows with no GE feed or palm kernel supplements.
This is why we welcome the opportunity to comment on the Next Steps for Freshwater consultation document (the document) which contains the Government’s proposals to improve freshwater management in New Zealand. This submission mainly focuses on the ‘Fresh water and our environment’ section of the document, which proposes to amend the National Policy Statement for Freshwater Management (NPS-FM) to improve national direction on several areas. This submission also addresses some other sections in the document.
Soil & Health supports a number of proposals in the document and believe that they have the potential to improve the management of freshwater in New Zealand. These include proposals for measuring water quality by catchment rather than region, and to exclude stock from waterways through regulation. However Soil & Health has concerns with some of the proposed amendments to the NPS-FM.
Detailed submissions
Weak bottom lines
Soil & Health opposes the proposed national bottom line for human health contained in the National Objectives Framework (NOF), that water bodies be safe for secondary contact i.e. wading and boating. We believe that the bottom line for human health in fresh water bodies should be that they are safe for primary contact i.e. for swimming. No incentive has been proposed to lift water quality standards beyond ensuring waterways are safe to wade in. We need stronger bottom lines for freshwater to ensure that our waterways are safe for swimming, ecological health, and collecting food.
‘Maintain or improve overall’ water quality
Proposal 1.1
Soil & Healthsupports the proposal to amend the NPS-FM so that it measures water quality by a freshwater management unit, rather than across a region.
We propose however that the word ‘overall’ from Objective A2 NPSFM be deleted. This in effect would remove the ability to have ‘unders’ and ‘overs’. We instead propose that objectives and limits be set so that water quality is maintained or improved at all points of all freshwater bodies, and nowhere are they set below national bottom lines. The ‘unders and overs’ approach has been rejected by the Parliamentary Commissioner for the Environment1 and the Environment Court. 2 It is inconsistent with section 6 and section 30 of the RMA. It is unworkable because of the practical difficulties in assessing what beneficial effect would counterbalance an adverse effect. If the ‘unders’ and ‘overs’ provision is retained, Soil & Health proposes that the Government provide guidance on how to maintain overall water quality at the required scale.
We also propose that there be a mandatory standard for dissolved inorganic nitrogen and phosphorus within catchments.
Macroinvertebrate Community Index as a measure of water quality
Proposal 1.3
Soil & Health supports the use of a ‘Macroinvertebrate Community Index’ (MCI) in the NOF, as a measure of water quality, and that it be adopted as a mandatory method of monitoring ecosystem health.
Proposal 1.4
We propose that use of MCI be included as an attribute in the NOF. Biological and ecological measures are essential attributes for which the MCI provides.
Significant infrastructure and water quality
Proposal 1.5
Soil & Health opposes the provisions in the NPS-FM that provide for exceptions to meeting the national bottom lines for significant infrastructure, and believe they should be repealed. However if the provision allowing exceptions to meeting national bottom lines for significant infrastructure remains in the NPS-FM, we strongly support the statement in the Consultation document that ‘Any exceptions would require public consultation.’
Intermittently closing and opening lakes and lagoons (ICOLLs)
Proposal 1.6
Soil & Health supports the proposal to amend the NPS-FM so that water quality attributes, including the national bottom lines, apply to ICOLLs.
Stock exclusion from water bodies
Proposal 1.8
Soil & Health supports the creation of a national regulation that requires exclusion of stock from water bodies. However stock exclusion needs to happen as soon as possible if it’s going to have any real effect on waterways. The current deadlines proposed by the Government do not provide any incentive for change. We also propose that clear guidance around the application of the regulation be required, otherwise implementation, monitoring and enforcement will become problematic. We furtherpropose that this regulation override existing provisions in District Plans. Finally we propose that riparian buffers be required as part of the national regulation.
Technical efficiency and good management practice standards
Proposal 2.1
Soil & Health supports the Government’s proposal to develop national technical efficiency standards.
However wepropose that the technical efficiency standards be introduced to all water catchments, not just in full allocation, or approaching full allocation, catchments. While there may still be some small permitted takes that will be difficult to monitor for efficiency standards, the expectation should still be that all water uses are using water efficiently.
Proposal 2.2
Soil & Health supports the Government’s proposal to develop national standards for good management practices.
However wepropose that the good management practices standards be the minimum requirement for all industries in all catchments, not just for discharge allowances that have been allocated, or in catchments that are over-allocated, or approaching over-allocation. Currently the good practice management standards are vague and the document does not set out how these will be established in regulation, nor how they will be modelled or monitored. More work needs to be done in this area and the Government needs to be leading the implementation of this nationally.
Addressing over-allocation and over-use at least cost
Proposal 2.5
Soil & Health strongly supports the proposal to develop guidance on different methods of addressing over-allocation of water quality and/or quantity, if technical efficiency standards and good management practice standards are insufficient.
We also propose that the development of any guidance material involve the participation of the public and a range of stakeholders, including Regional Councils.
Freshwater decision-making
Proposal 3.6
Soil & Health strongly opposes allowing the Minister for the Environment to delay an application for a Water Conservation Order (WCO). WCOs are about protecting outstanding features of water bodies. If those outstanding features exist then they shouldn’t be undermined by a planning process, which is required to protect them anyway.
Conclusion The Soil & Health Association strongly opposes the inclusion of the proposed bottom line for human health that water bodies be safe only for secondary contact, into the National Policy for Freshwater Management on the grounds that waterways must be able to support a good standard of ecological health. That standard should also equate to being safe for humans to swim, play, and gather food from fresh waterways.
Yours sincerely
Name: Marion Thomson
Position: Co Chair
The Soil & Health Association
PO Box 340002
Birkenhead
Auckland 0746
Phone: 06 8775534 Mobile: 0275554014
Email: advocacy@organicnz.org.nz
Website: www.organicnz.org.nz
1 Parliamentary Commissioner for the Environment, Managing water quality: Examining the 2014 National Policy Statement, June 2015, pages 6-8. 2 Ngati Kahungunu Iwi v Hawkes Bay Regional Council [2015] NZEnvC 50. The references in paragraph 2.9 come from [62], [63], [104], [105].
Submission on Animal Welfare Regulations
/in SubmissionsSubmission on Animal Welfare Regulations by the Soil & Health Association
Ministry for Primary Industries
PO Box 2526
Wellington 6140
FROM: The Soil & Health Association
PO Box 340002
Birkenhead
Auckland 0746
Phone: 0212667754
Email: advocacy@organicnz.org.nz
Website: www.organicnz.org.nz
Submission on Animal Welfare Regulations by the Soil & Health Association
Introduction
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.
Soil & Health recognises that New Zealand animal welfare standards need improving. Every year thousands of animals in New Zealand are farmed intensively, fed high doses of antibiotics, and grains with herbicide residues, kept in unhygienic and cramped conditions, with high levels of stress and injury, unable to express normal behaviours, which runs contrary to the stated principles in the Animal Welfare Act 1999.
As an organic organisation we advocate for the highest animal welfare standards. Organic livestock farming is based on the harmonious relationship between land, plants and livestock, respect for the physiological and behavioural needs of livestock and the feeding of good-quality organically grown feedstuffs. We support the Five Freedoms as set out under the Animal Welfare Act 1999. We believe that any farming methods that cause animals to suffer or prevent them from expressing normal patterns of behavior should be phased out. This is why we welcome the opportunity to comment on the Proposed Animal Welfare Regulations discussion document (the document), which contains the Government’s proposals to improve the enforceability, clarity and transparency of the animal welfare system in New Zealand.
The current animal welfare system does not deal properly with lower-level offending. Soil & Health supports the majority of the proposed regulations in the document in general as they enable the Ministry for Primary Industries to better enforce compliance with the Animal Welfare Act 1999. These include proposals for increasing penalties and infringement fees for offences. However Soil & Health has concerns with some of the proposed regulations and believe that a number of cruel practices outlined, such as colony cages and farrowing crates, should be phased out and prohibited altogether.
Detailed submissions
10. – Care and Conduct Regulatory Proposals
All Animals
1. Electric prodders
Soil & Health supports the proposed regulation in part. Electric prodders are a cruel device. We oppose the exceptions of their use for cattle over 100kg, at a commercial slaughter premise, and for a circus. We believe that alternatives should be found for the intention of moving animals and that electric prodders should only be used when the safety of the handler is at risk. We believe that restrictions should be placed on the possession and sale of electric prodders, as these devices are freely available and sold online with no requirement for information or training to be provided to purchasers. We do however support the proposal being placed in regulation as it means it will be directly enforceable.
2. Use of goads
Soil & Health supports the proposed regulation to prohibit the use of goads to prod an animal in the udder, anus, vulva, scrotum or eyes. The use of goads to move animals causes the animals to become nervous and fearful. The use of electric goads and physical goads such as sticks will obviously cause pain. We support placing the prohibition in regulation as it means it will be directly enforceable.
3. Twisting an animal’s tail
Soil & Health strongly supports the proposed regulation to prohibit twisting the tail of an animal in a manner that causes the animal pain. Tail twisting is an unnecessary and cruel practice often used to restrain and move animals and can risk leading to tail breaking, which causes pain and distress. We support the regulation as it provides an enforceable deterrent to tail twisting.
Goats
13. Tethered goats
While Soil & Health does not support the tethering of goats generally, as they are naturally foraging herd animals and tethering them prevents them from expressing their natural instincts to roam and forage freely, we do support the minimum requirement of constant access to food, water and shelter if tethered. However we believe that the word ‘shelter’ needs to be further defined. Shelter must be defined as providing a space that is clean, dry and has adequate space. As stated in the document, goats are more susceptible to hypothermia than sheep therefore the definition of shelter must also include providing protection from the natural elements including wind and rain, and weather extremes such as snow and hail.
Layer hens
17. Opportunity to express normal behaviours in housing systems
Soil & Health supports the new requirements under 17(a) that hens must have the opportunity to express a range of natural behaviours, becoming part of regulation and thereby becoming directly enforceable.
18. Stocking densities
While Soil & Health supports the proposed stocking regulations becoming part of regulation, thereby making them directly enforceable, we are strongly opposed to the specific stocking densities set out under 18. We believe that stocking hens at this density will not allow them the opportunity to express the range of natural behaviours outlined under 17(a). We believe that for hens to express the range of natural behaviours outlined under 17(a) they must be stocked at 6 birds per m2, with a minimum of 18 cm perch space provided for each bird.
19. Housing and equipment design
While Soil & Health supports the housing and design regulations becoming part of regulation thereby making them directly enforceable, we are strongly opposed to the use of closed cages including colony cages for all poultry, not just laying hens. Closed cages do not allow the animals the opportunity to express the range of natural behaviours outlined under 17(a). Chickens are biologically omnivores and instinctively, when given the opportunity, actively forage for green growing plants, animal foods such as earthworms and insects, wild fruits and some seeds.We therefore believe that if we are going to allow hens the ability to express the range of natural behaviours outlined under 17(a) they must have unrestricted access to outside runs, with at least 50% of the outside run area covered with vegetation at all times, allowing the hens constant access to fresh grass or forage crop containing a diversity of species. We believe that all poultry sheds should have access to good pasture, and be situated to allow for rotation of grazing areas – for example mobile poultry sheds. We believe that adequate nesting space should be provided at a minimum of 7 birds per nest, and that perchesshould be available in all laying hen housing to a minimum of 18cm perch space per bird.
Pigs
24. Dry sleeping area
Soil & Health supports the proposal that pigs must have access to a dry sleeping area. Failure to provide a dry sleeping area can cause distress and ill health, particularly when a sow is pregnant and is trying to create a nest for her piglets. Furthermore pigs have clean toilet habits and in nature would never defecate near where they sleep. However if left in a confined area then pigs may be left to lie in their own excrement. Providing a dry sleeping area means this would not happen.
25. Lying space for grower pigs
Soil & Health strongly oppose the proposed lying space for grower pigs. We do not believe the proposed spacing will allow for improvement of overstocking behaviour issues such as aggression, nor allow for the pigs to express normal behaviours. Keeping pigs at this density does not allow them to roam, play or dig as they would naturally outdoors. We believe that all pigs should have access to outdoor pasture.
26. Dry sow stalls
Soil & Health strongly supports the prohibition of dry sow stalls and placing the prohibition in regulation thereby making it directly enforceable. Dry sow stalls are an inhumane and cruel practice. Pigs are highly intelligent, social animals. Keeping sows in individual stalls deprives them of their most basic needs such as fresh air, sunlight, clean water and soft bedding, as well as their need to socialise. We support this proposal as it places prohibition in regulation, making it directly enforceable.
27. Size of farrowing crates
Soil & Health supports the proposal as it places prohibition in regulation, thereby making it directly enforceable, however we strongly oppose the use of farrowing crates in general and believe that they should be banned altogether. Farrowing crates only allow the sow to either stand up or lie down, thereby preventing her to properly mother her piglets. This causes frustration and depression and is therefore an inhumane and cruel practice that we do not support.
28. Provision of nesting material
Soil & Health supports the use of nesting material in the farrowing system. As stated sows have a strong behavioural instinct to build a nest prior to farrowing. With no material for bedding she would scrape her nose over the bare concrete in an attempt to build a nest for her piglets. Not providing materials that the sow can manipulate prevents her from expressing natural behaviours. We therefore support this proposal as it means that any offences of not providing nesting material for sows will be directly enforceable. We however propose that the wording be changed to state “natural material”, which should be further defined with a list of specific natural materials to be used such as straw, twigs and grasses. We further propose that the nesting material be a mandatory requirement all the way through farrowing until after the piglets have been raised and weaned.
Cattle
31. Milk stimulation
Soil & Health were not aware of this practice still occurring however believe it is unnecessary and cruel. We support the proposal to prohibit stimulating milk let-down by inserting water or air into a cow’s vagina, and placing it in regulation thereby making it directly enforceable. We believe that it warrants regulation so that effective action can be taken if it occurs.
32. Cattle and sheep – vehicular traction in calving or lambing
Soil & Health supports this proposal to prohibit using a moving vehicle to provide tractions in calving or lambing, making it part of regulation thereby making it directly enforceable. We believe it is an unnecessary and unnatural technique that has a high risk of causing injury, pain and distress to both the young and the mother. We support animals birthing naturally without artificial stimulation and force. We believe that it warrants regulation so that effective action can be taken if it occurs.
11.0 Young calf management regulatory proposals
43. Loading and unloading facilities
Soil & Health supports the proposed regulation that facilities must be provided to enable young calves to walk onto and off transportation by their own action. However we believe that the regulation needs to specify acceptable methods of loading and unloading, for example stating that they must be ramps, or electronic lifts. We do not believe that the regulations should allow for flexibility for other methods that would enable calves to walk onto and off vehicles, as this may allow for breaches of welfare. We believe all acceptable methods should be specifically stated to provide for full clarity. Further we believe that the time period to allow farmers and other businesses to make arrangements necessary to put suitable loading and/or unloading facilities in place should not be more than 12 months.
44. Shelter on-farm, before and during transportation and at processing plants
Soil & Health supports the proposed regulation in part. We believe that the regulation on shelter should also cover the stocking density of animals in pens. Stocking density should be at a rate that provides enough room for all calves to lie down.
45. Fitness for transport – age
Soil & Health opposes the proposed regulation that young calves must not be transported for processing and slaughter until they are at least four days of age. We believe four days old is an unacceptable age, being too young for travel. As stated in the document the four-day minimum age is not a guarantee that individual calves will be in a suitable physical condition for transportation. While the intention is for the regulation to be read together with those regulations for the physical condition of young calves we do not believe this will happen in practice, and it will also make it more difficult to enforce. We propose that the age be lifted to match that of the European Union of 10 days old, rising to 14 days old for longer journeys over eight hours. Raising the age to 10-14 days means that there is a strongly likelihood that the young calf will be in a suitable physical condition for transportation.
46. Fitness for transport – physical characteristics
Soil & Health supports this proposed regulation. However as stated above we believe by raising the minimum age for transportation to 10-14 days old that this will help to ensure that the young calves are in suitable physical condition for transportation.
47. Maximum time off feed
Soil & Health supports this proposed regulation to reduce the amount of hours off feed from 30 to 24 however we believe that 24 hours is still too long to go without feed for young calves. Naturally a young calf would feed from their mother every 2 to 3 hours. Calves began to feel hunger soon after 3 hours from their last feed, when plasma glucose begins to decline. Hunger then increases gradually for the next 15 hours and then rapidly over the final 12 hours. Leaving young calves without feed for such a long duration is cruel, and also leaves them physically weak. We believe that 24 hours is an unreasonable maximum period to permit young calves to be off feed when being transported prior to slaughter. We propose that the time period be reduced below 24 hours.
48. Duration of transport
Soil & Health supports the proposed regulation to reduce the maximum amount of time a young calf spends in transportation from 12 hours to 8 hours.
49. Blunt force trauma
Soil & Health supports the proposed regulation to prohibit the use of blunt force trauma for killing calves.
50. Transport by sea across Cook Strait prohibited
Soil & Health supports the proposed regulation to prohibit the transportation by sea of young calves across the Cook Strait. We believe that the infringement fee of $500 rather than $300 is a suitable penalty.
12.0 Surgical and painful procedures regulatory proposal
66. Cattle – tail docking
Soil & Health supports the proposed regulation to prohibit tail docking of cattle. We believe it is a cruel and unnecessary procedure especially when there are other alternatives such as switch trimming. Tail docking can lead to significant health problems, including incontinence, hernias, phantom tail pain and increased sensitivity to pain. Further more tail docking does not improve cow hygiene. Tail docking on cattle is a purely anthropocentric procedure that improves comfort for milking personnel only. We support the proposed restrictions that tail docking only is performed for therapeutic purposes (i.e. in response to disease or injury), that a veterinarian or a veterinary student under the direct supervision of a veterinarian must perform it, and that pain relief must be used at the time of procedure.
67. Cattle and sheep – castration and shortening of the scrotum
Soil & Health supports this proposal in part. We propose that castration and shortening of the scrotum only be permitted at a young age of less than 6 months. Castration beyond 6 months of age should be banned. We support the proposed regulation that only conventional rubber rings must be used for this procedure as it helps to minimise the level of pain and distress an animal experiences. We also support the use of pain relief at the time of the procedure.
69. Cattle, sheep, & goats – dehorning
Soil & Health supports this proposal in part. We propose that dehorning only be permitted in the budding stage. Dehorning is a painful procedure. Studies have shown that dehorning stimulates both an acute pain response and a delayed inflammatory reaction. Young animals tend to recover quicker and have fewer complications than animals dehorned at an older age. It is generally accepted that the younger the animal, the less painful the procedure. We do however support the proposal to make pain relief mandatory at the time of the procedure.
70. Sheep – tail docking
Soil & Health supports this proposal in part. We propose that tail docking be banned on sheep i.e. over 12 months of age. We understand that tail docking of sheep has benefits such as reducing problems like fly strike. However tail docking is a painful procedure so restricting it to lambs will result in less pain and therefore reduce the impact of the procedure on the animal. We support the rest of the proposals for tail docking under 6 months of age and tail docking over 6 months of age and believe it provides a clear mandatory standard for the procedure. However we believe that the tail length should be further specified as the current wording “must not be cut flush” is unclear and confusing.
71. Sheep – mulesing
Soil & Health strongly supports the proposal to prohibit mulesing of sheep and placing this prohibition in regulation, thereby making it directly enforceable. This procedure is one of the most barbaric and cruel practices carried out in the farming industry. It is an extremely painful practice and lambs have been seen to demonstrate abnormal behaviour indicative of extreme pain for days afterwards. We believe that the most humane alternative to sheep mulesing is to breed sheep to have low wrinkles, fewer dags and less wool around their breech, and that this should be a stated objective. Other effective alternatives are tailing docking of lambs, timing of shearing and crutching, effective natural control of scouring (especially the control of intestinal worms), strategic application of natural treatments to prevent flystrike, and regular inspection of the flock especially daily during high risk periods.
72. Deer – develvetting
Soil & Health opposes this proposal, as we believe that the develvetting of deer should be prohibited. However if it is to go ahead we do not believe that farmers should undertake this procedure themselves, even if given veterinary approval. It should be made mandatory that only a vet or veterinary student under direct veterinarian supervision should undertake this procedure.
74. Horses – tail docking
Soil & Health supports the proposed regulation to prohibit tail docking of horses. We believe it is a cruel and unnecessary procedure. We support the proposed restrictions that tail docking only is performed for therapeutic purposes (i.e. in response to disease or injury), that a veterinarian or a veterinary student under the direct supervision of a veterinarian must perform it, and that pain relief must be used at the time of procedure.
80. Pigs – castration
Soil & Health supports this proposal in part. We propose that castration of pigs only be permitted at a young age of less than 6 months. Castration beyond 6 months of age should be banned. We support the proposed regulation that a veterinarian or a veterinary student under the direct supervision of a veterinarian must perform the procedure, and that pain relief must be used at the time of procedure.
81. Pigs – tail docking
Soil & Health opposes the regulation to allow for tail docking of pigs. We believe it is a cruel and unnecessary practice. The reason tail docking of pigs is performed is to reduce the incidence of tail biting. However tail biting is a result of keeping pigs in high-density stocking numbers and pigs become frustrated and distressed. Pigs are highly intelligent, inquisitive animals and need intellectual stimulation such as natural material to play with. Studies have shown that providing straw or other manipulable materials and keeping a lower density of pigs in a pen could largely prevent tail biting.
Conclusion
As set out above, Soil & Health supports the majority of the proposed regulations in in the document in general, however we oppose a number of the proposed regulations as they either prevent animals from expressing normal patterns of behaviour, or they are cruel mutilation practices that cause harm and distress, thereby running contrary to the Animal Welfare Act. We believe that animals should not be kept in closed cages. Instead all animals should have unrestricted daily access to pasture. We therefore strongly oppose the use of colony cages for poultry and farrowing crates for pigs and believe they should be prohibited. In summary, while we commend the government for their efforts to tighten animal welfare regulation and create better enforcement with the Animal Welfare Act, we believe there is still much room for improving New Zealand’s animal welfare standards to better meet the physiological and behavioural needs of animals.
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
Organic dairy farmers reaping just rewards
/in Farming, Media Releases, OrganicsThe huge rise in the milk payout to organic dairy farmers is a welcome encouragement for the dairy sector to move towards clean, green and high-value production, according to the Soil & Health Association.
Fonterra just announced a big jump in the milk payout to organic farmers, due to increasing global demand. For the 2016-17 season organic farmers will receive $9.20 per kg of milk solids, up from the current organic price of $5.65. Non-organic milk solids fetch just $3.90.
“Consumers worldwide are demanding safe, healthy food, and are prepared to pay for high quality, GE-free, organic dairy products,” said Marion Thomson, co-chair of Soil & Health.
“It’s great to see Fonterra responding to this demand,” Thomson said. “Their announcement is a much more positive backing of organic dairy farmers than we have seen from them in the past.”
New Zealand organic dairy consumption mirrors the global trend. Domestic organic milk sales reportedly rose by 50% in 2014, according to the recently released NZ Organic Market Report. Nearly all the growth in domestic milk sales in 2015 came from organic milk (https://drive.google.com/file/d/18f0vUhTC4w8HMZ1o_I4Kg5Uy7_applRv/view?usp=sharing
To meet the demand, Soil & Health says organic milk processing needs to be more widely accessible in all regions, including the South Island.
Soil & Health expects to see increased interest from farmers in converting to organics.
“Organic dairying not only brings in a decent income for farmers, it also results in cleaner rivers and healthier people,” said Thomson.
Organic dairy farms have a lower environmental footprint than conventional farms, with improved soils and reduced nitrate leaching, resulting in cleaner waterways. Organic farms have lower greenhouse gas emissions and greater carbon capture in the soil. They have lower stocking rates, but receive a premium for a high-value, healthy product.
“To help farmers make the transition to organics, Soil & Health would like to see the government reinstate the successful organic advisory programme,” said Thomson. “New Zealand urgently needs to shift away from environmentally unsustainable farming practices and big irrigation schemes, and instead focus on sustainable farming.”
About two thirds of producers who took up the organic advisory programme went on to convert to organics.
NOTE:
The Organic Advisory Programme was established as part of an agreement between the Green Party and Labour Government, and ran from 2006–2009. http://www.scoop.co.nz/stories/BU0906/S00692/organic-advisory-programme-ends.htm
MEDIA CONTACT
Marion Thomson, co-chair, Soil & Health
027 555 4014
advocacy@organicnz.org.nz
Organic farming will revitalise waterways
/in Media Releases, WaterThe two most crucial moves we can make to improve New Zealand’s sadly degraded waterways are to stop dairy expansion, and to transition towards truly sustainable farming, according to the Soil & Health Association. Organic farmers are well ahead of the game in sustainable production and provide a model for a positive, healthy future for New Zealand. The latest issue of Soil & Health’s magazine, Organic NZ, includes an article ‘Dairy farming without nitrate leaching’ (May/June issue, just released this week).
“New Zealand’s waterways are in a dire state, with many showing a continuing deterioration in water quality, and no clear path for improvement.” said Marion Thomson, co-chair of Soil & Health. “The main driver of this is the increasing intensification of non-organic farms, and we urgently need to turn this around.”
“Organic and biological farming systems have a much lower ecological footprint, greater biodiversity and reduced nitrate leaching, making waterways healthier for all to enjoy,” she said.
Soil & Health welcomed the opportunity to submit on the consultation document “Next Steps for Fresh Water” which forms part of the Government’s freshwater reforms. The document outlines a range of bottom lines that healthy rivers must not fall below. One of these measures is human health, and the bottom line is that waterways must be safe for secondary contact, i.e. wading or boating.
“Weak bottom lines such as this will only allow water quality to decline,” said Thomson. “The bottom line must be swimmable rivers, and this needs to be a national target.”
However, given thata big factor in the pollution of waterways is nitrates from cow urine diffusing through soils, and from soluble nitrogen fertilisers, simply fencing off and planting around streams cannot solve this issue. Healthier fresh wateris achievable by ensuring stock numbers are sustainable, and by shifting to organic and biological fertilising practices that involve nitrogen-fixing pasture species, and healthy living soils with good moisture-holding capacity.
Soil & Health supports a number of other proposals in the consultation document that it believes have the potential to improve the management of freshwater in New Zealand. These include proposals for measuring water quality by catchment rather than region, and to exclude stock from waterways through regulation.
Media contact:
Marion Thomson
Co-chair, Soil & Health
027 555 4014
advocacy@organicnz.org.nz
Together we can keep Aotearoa GE-free!
/in GE, GM, Media Releases, Organic CommunityOne of the world’s oldest organic organisations is now using crowdfunding to help keep New Zealand’s valuable GE-free status.
The Soil & Health Association of New Zealand, founded in 1941, has just launched a Givealittle page to appeal for donations from a wide range of Kiwis who want a clean, green, GE-free Aotearoa.
Recently, Soil & Health has been defending the rights of councils to control the use of genetically modified organisms (GMOs) in their regions under the Resource Management Act.
Soil & Health’s new Givealittle page will help Kiwis contribute towards the costs involved in the High Court case held in Whangarei in February 2016. Soil & Health joined with others in the High Courtto protect Northland Regional Council’s ability to decide whether or not GMOs are released or field-trialled in Northland and, if so, whether any conditions should be placed on them. Soil & Health anticipates similar court cases in the future, so is also seeking funds now in preparation for these.
Any donations or financial support would be greatly appreciated and can be made viahttps://givealittle.co.nz/cause/soilandhealthstandagainstge.
Together we CAN keep Aotearoa GE-free!
For more information on the court case, visit: https://soilandhealth.org.nz/node/1102
For more information and GE and GMOs, visit: https://soilandhealth.org.nz/node/571
Celebrating 75 years of organics in NZ
/in Media Releases, Organic Community, OrganicsCutting an organic cake at Parliament today marked the 75th anniversary of the Soil & Health Association, one of the world’s oldest organic organisations. The cake ceremony was a highlight of the launch of the OANZ 2016 New Zealand Organic Market Report.
“We’re so proud to be part of a movement that is championing healthy soil, healthy food and healthy people,” said Marion Thomson, co-chair of Soil & Health.
According to the Organic Market Report, two out of every three Kiwis are buying organic products. The organic sector in New Zealand has grown by 11% per annum every year since 2012, being driven by consumer demand, which is outstripping supply. Organic grocery sales through supermarkets have increased by 127% since 2012.
“More and more people are looking for organic food, which gives assurance that it is safe, healthy, environmentally conscious and GE-free,” said Marion Thomson.
“The report is a powerful validation of the growing strength of organics when it comes to Soil & Health’s legal cases, as we defend the rights of communities via their councils to retain the right to be GE-free, or determine the use of any outdoor GMOs in their areas,” she said.
The Soil & Health Association has, since it was founded in 1941, promoted organic gardening and farming methods, healthy food and good nutrition. It is the largest organic membership organisation in New Zealand, and publishes Organic NZ magazine.
Natural Health & Supplementary Products Bill – Ministry of Health’s consultation paper ‘The Regulation of Natural Health Products’
/in SubmissionsSubmission 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.
Submission in opposition to clause 105 of the Resource Legislation Amendment Bill 2015
/in Submissions14 March 2016
The Committee Secretariat
Local Government and Environment Select Committee
Parliament Buildings
Wellington
Submission in opposition to clause 105 of the Resource Legislation Amendment Bill 2015
Introduction
Detailed submissions
Genetically Modified Organisms
[48] … I find that there is nothing present in these pieces of legislation to prevent the establishment of objectives, policies and methods to achieve integrated management of natural and physical resources in the broad terms directed by the RMA.
[49] I consider that there is a readily identifiable policy reason for that in these pieces of legislation, read together. Once having been approved for import and release into New Zealand under HSNO, regional authorities can provide for use and protection of them together with other resources in a fully integrated fashion, taking account of regional needs for spatial management that might differ around the country for many reasons, not the least of which might include climatic conditions, temperatures, soils, and other factors that might drive differing rates of growth of new organisms and/or of other organisms, as just a few of perhaps many examples. I agree with the opposition parties that the RMA and HSNO offer significantly different functional approaches to the regulation of GMOs.
Conclusion
Yours sincerely
Name: Marion Thomson
Position: Co Chair
The Soil & Health Association
PO Box 340002
Birkenhead
Auckland 0746
Phone: 06 8775534
Mobile: 0275554014
Email: advocacy@organicnz.org.nz
Website: www.organicnz.org.nz
GE: it’s our right to decide
/in GE, GM, Media ReleasesCommunities should have the right to decide whether or not genetically modified organisms (GMOs) are released or field-trialled in their regions and, if so, whether any conditions should be placed on them, say the Soil & Health Association and GE Free Northland.
The two organisations again joined forces with Taitokerau mana whenua and others in court this week, responding to another case on the GMO issue brought by Federated Farmers, this time to the High Court in Whangarei. The judge’s decision is expected within a month.
“New Zealand has already seen inadequately contained GE field trials, in breach of the conditions of approval,” said Zelka Grammer, GE Free Northland chairperson. “We stand in support of the member councils of the Northland/Auckland Inter Council Working Party on GMOs, who are acting responsibly on their duty of care to the environment and constituents.”
“Federated Farmers claims to represent farmers, but many primary producers – organic and non-organic – are selling to high-value national and international markets that have zero tolerance for GE contamination,” said Marion Thomson, co-chair of Soil & Health.
Federated Farmers appealed the Environment Court decision in May 2015 that regional councils have the power under the Resource Management Act (RMA) to control the use of GMOs via regional planning instruments.
The Environment Court decision came about after Federated Farmers opposed Northland Regional Council’s proposed Regional Policy Statement, which included provisions relating to the use of GMOs in the region, and specifically included a policy requiring that a precautionary approach be taken to the introduction of GMOs.
Federated Farmers’ lawyer Richard Gardner argued in the High Court that central government passed the Hazardous Substances and New Organisms Act (HSNO) Act specifically for the purpose of controlling GMOs, and that parliament could not have intended for councils to duplicate that role under the RMA.
Soil & Health, GE Free Northland, Taitokerau mana whenua, Far North District Council and several other groups and individuals joined the appeal as section 274 (interested) parties pursuant to the RMA, in support of appellant Whangarei District Council. They were represented by Dr Royden Somerville, QC (senior counsel), and Robert Makgill (legal counsel).
Dr Somerville argued that Environment Court Judge Newhook was correct in his decision that the RMA and HSNO Act hold complementary and not overlapping roles. The two Acts offer different purposes and functional responses to the regulation of GMOs in New Zealand. Thus, regional planning documents can control the use of GMOs as part of promoting sustainable management under the RMA, taking account of regional needs.
The HSNO Act has a more confined role of regulating the granting (by the Environmental Protection Authority – EPA) of approvals to import, develop, field test or release new organisms as a ‘one-off’ regulatory transaction. The regulatory functions of the EPA under the HSNO Act do not allow for the provision of a regional approach to GMOs. That can only be dealt with under the RMA by regional councils and unitary authorities through policy statements and plans.
MEDIA CONTACTS:
Marion Thomson, co-chair, Soil & Health, 027 555 4014
Zelka Linda Grammer, chairperson, GE Free Northland, 022 309 5039