Submission of the Soil & Health Association on the Therapeutic Products Bill

The Therapeutic Products Bill is intended to replace the Medicines Act 1981 and Dietary Supplements Regulations 1985 and brings natural health products (NHP) into the regulation system for health products within Aotearoa/New Zealand. 

Read our full submission here.

Summary of our submission

This submission from Soil & Health focuses on the regulation of natural health products. 

Soil & Health agrees with the Purpose of the Therapeutic Products in relation to natural health products: 

‘to protect, promote, and improve the health of all New Zealanders by providing for the—… 

acceptable safety and quality of natural health products across their life-cycle. 

but we consider that the Bill is written primarily from a western reductionist viewpoint, considering natural health products rather than natural health systems: 

  1. Much of the Bill is concerned with defining therapeutic products and decisions on this will be made by experts in the field.  Soil & Health is concerned that registered naturopaths, medical herbalists and homeopaths are not included as health practitioners under the Health Practitioners Competence Assurance Act 2003, nor are they recognised as experts in natural health products in this Bill. In contrast pharmacists are recognised in the Bill and sell natural products although they are not trained as experts in this field.  

We recommend that the Naturopaths & Medical Herbalists of NZ (Inc).(NMHNZ)(https://naturopath.org.nz), New Zealand Association of Medical Herbalists (NZAMH) (https://nzamh.org.nz/) and the New Zealand Council of Homeopaths (https://homeopathy.co.nz/) be recognised as responsible authorities under the HPCAA and that those registered by these authorities be included in the Bill as NHP practitioners. 

  1. The Bill allows for the definition of natural health products to include synthetic ingredients and additives. 

We recommend synthetic ingredients and additives be limited to 5% of the product and controlled. 

  1. The Bill also allows for exceptions to the requirement for regulations for low concentration natural health products. 

Soil & Health recommends that the risk assessment of dilute NHPs such as homeopathic remedies apply not to the origin of the remedies (whether plant, mineral or animal), but instead to the final products, which contain no DNA and therefore no disease risk.  

  1. We recognise that large manufacturers of natural health products want and need regulations for export. BUT it is our view that these market regulations should not apply to the domestic market.   

We recommend that a list of prohibited ingredients be developed for the domestic market.   

  1. The Bill currently applies to rongoā.   

We recommend that the Bill not proceed until there is a Tiriti-based process in place for rongoā. 

  1. The Bill does not provide any protection for source ingredients.   

Soil & Health recommends that plant ingredients be harvested in a way that protects their sustainability and avoids depletion of any endangered species. 

Goodbye Glyphosate! Rethinking Weeds

Learn how to eliminate glyphosate and other harmful herbicides.

This recording is available to members, below. Please log-in using the email associated with your membership. If you have trouble logging-in please contact our team by email: info@organicnz.org.nz

About the video

This webinar is part of the Soil & Health Association’s campaign to strengthen regulation of glyphosate: https://soilandhealth.org.nz/glyphosate/

Join Philippa Jamieson, former editor of Organic NZ magazine, in conversation with Dr Charles Merfield and Mike Palmers who will discuss the way we think about and experience the plants we call “weeds”, and offer some organic, non-chemical and agro-ecological ways of managing them.

Followed by questions and discussion about practical weed solutions for your home garden, small block or farm.

The panelists

Dr Charles Merfield is head of the BHU Future Farming Centre and Merfield Agronomy Ltd. He has a particular interest in physical and ecological weed management.

Mike Palmers is an organic landscape gardener, he is currently a member of Soil & Health’s national council, and has served on the board of BioGro.

Video series

Suggested donation $10 – funds go towards Soil & Health’s glyphosate campaign. Make your donation by credit card: https://soilandhealth.org.nz/donate/#!form/Donate

Or transfer funds to our account: BNZ Account number: 02 0108 0058415 001

Ben Cheah’s half acre garden of peace & plenty

This is a four-part video series of Ben Cheah’s Auckland garden.


Counting earthworms at Tapu Te Ranga

Event grants for Soil & Health members

The Soil & Health Association will provide a grant of up to $100 for the running of any public event led and organised by an association member.

Grant conditions

  • Applications for grant funding must use the form provided below 
  • Applications should show how the proposed event will deliver benefits to one or more of the strategic priorities of the Soil & Health Association: Organic regenerative agriculture; Climate change; Healthy Food; Cohesion and unity 
  • Events must be open to the general public 
  • Any information, photography, video or material resulting from the event should be made available to the Association. 

Apply now

These grants are available to any Soil & Health member

Please complete the grant application form and email it to manager@organicnz.org.nz

Note: the total amount of grant funding available is limited to a total of $1200 over one financial year, the Association will take this limit into account when considering applications. 

2022 AGM of the Soil & Health Association

Event details

The 2022 AGM was held in Wellington on September 24th as part of a two-day event with Organics Aotearoa New Zealand (23-24 September)

The AGM began at 9.15am at the Prefab Hall, 14 Jessie Street, Te Aro, Wellington

Virtual attendance (via Zoom) was combined with in-person attendance

Draft minutes

The draft minutes of the 2022 AGM re available here: Draft minutes of the 2022 AGM

Agenda

  • Welcome and light refreshments
  • Attendees and apologies
  • Minutes of 2021 AGM
  • Election of National Council
  • Reports
  • Soil & Health strategic plan presentation
  • Updating our constitution (discussion item)
  • Remits
  • Nomination of Philippa Jamieson for honorary life membership
  • General business (from the floor)
  • Election Results
  • Close meeting (by around 11am)

Papers

*Note: the audit report and audited accounts are still pending.

Nominations for National Council

The following nominations were received for four vacant positions on national council.

  • Barbara Collis
  • Don Hunter
  • Charles Hyland
  • Marion Wood

These candidates were all elected at the AGM

Constitution update

We discussed a process to update our constitution, with a view to developing and then finalising any changes at next year’s AGM (2023). This work is prompted by new regulations set out by government this year

Remits

The following remits were agreed upon at the meeting:

Remit 1 (Alison White/Claire Bleakley) – Urge set up of Technology Ethics Council

That the Soil & Health National Council write to appropriate MPs in all the major political parties to urge them to (re-)establish a Technology Ethics Council that would deal with emerging technologies such as gene editing, gene therapies and their various uses, synthetic biology, nanotechnology, geoengineering and artificial intelligence.

Rationale: These new technologies are set to quite possibly negatively impact all aspects of life and the environment, and in particular present new challenges to the principles and values of the organic community. Since the disestablishment of the Bioethics Council, Toi Te Taiao, in 2009, there has been no body of independent experts overseeing the moral or ethical impacts of such technologies in New Zealand. Commercial pressures risk the voices of the organic community, tangata whenua and diverse communities being silenced or misled. We note with concern the immediate global push by powerful interests to deregulate gene editing (such a bill is currently before the UK parliament), with consequences including unlabelled food and a potential threat to organic growing. NZ and overseas organic standards do not permit any GE contamination threshold.

Remit 2 (Alison White/Claire Bleakley) – Climate change & organic agriculture

That the Soil & Health National Council write to appropriate MPs in all the major political parties to emphasise to them how vital a role that carbon cycling in a healthy soil and organic agriculture in particular can play in mitigating New Zealand’s role in climate change.

Rationale: As one of the oldest and leading proponents of organic growing in New Zealand, Soil & Health has a responsibility to raise awareness of the importance of soil health in relation to reducing carbon in the atmosphere. There is a risk that industry sectors will push high tech and profit-making solutions at the expense of a healthy and diverse ecosystem. For too long organic agriculture has been sidelined by the Government, except for exports.

Philippa Jamieson HLM nomination

The Soil & Health national council was delighted to nominate Philippa Jamieson for an honorary life membership. Philippa has played a key role in the work of soil and health over many years, including a pivotal contribution as magazine editor. The HLM nomination was confirmed at the AGM.

Field Trip to Piha to visit the Waygood Foundation’s Gardens and Beck Wheeler Garden.

These are two three-part video series, one for the Waygood Foundation garden and one for the Beck Wheeler garden

A group from Soil & Health Auckland visited two Permaculture Gardens in Piha on Saturday the 12th Feb 2020. We visited the Waygood Foundation Gardens where Claire Inwood guided us on a tour of the property. On a sandy based soil they have created a series of gardens, original, new, terraced and a Kids garden. These mixed gardens of vegetables, herbs, flowers and fruit trees are nestled in a glade of Pohutukawa trees.

Ben Cheah Speakers Meeting

Ben Cheah speaks about Small Urban Gardens.

This is a three-part video series

Wake-up call on the environmental and human health harms of toxic agrichemicals

The Soil & Health Association is welcoming last week’s “Knowing what’s out there” report by the Parliamentary Commissioner for the Environment. The report criticises New Zealand’s lack of monitoring and regulation of environmental harm from chemicals.

Jodie Bruning, national councillor for the Soil & Health Association

“New Zealand lags behind other countries on monitoring and regulation of toxic agrichemicals, putting our health, environment and overseas trade agenda at risk,” says Soil & Health spokesperson Jodie Bruning.

“A more integrated framework, suggested by the report, will help the right hand know what the left hand is doing, this is currently not happening in New Zealand, when it comes to environmental chemicals.

“For example the Environmental Protection Agency, our government watchdog on these issues, had to make a public appeal last year for information on glyphosate use. Why do they need to resort to this?  Because they don’t monitor glyphosate’s use, availability, or impacts. There’s no feedback loop between the agencie and our territorial and local authorities.

“It’s been shown that glyphosate is a probable carcinogen and its widespread use in New Zealand must be stopped. 

“Glyphosate is the tip of the iceberg. Our regulatory settings are useless if we are not informed about environmental pollution, and if regulator is not keeping an eye on what’s happening on the ground.

“The government needs to take this report seriously. This includes expediting a formal reassessment of glyphosate as a key next step in protecting New Zealanders and the natural environment from harm.”

ENDS

Notes

The PCE report is covered here: https://www.rnz.co.nz/news/national/462653/lack-of-mechanisms-to-govern-chemical-use-in-nz-commissioner

Sanctuary gardens visit April 2021

We visit sanctuary gardens and hear from manager Trevor Crosby

This is a two-part video series

Dee Pigneguy’s organic home garden

A visit to Dee’s home organic garden 27 Oct 2018