EPA Call for Information on glyphosate, September 2021

Summary of our submission

A GLYPHOSATE RISK ASSESSMENT IS NEEDED URGENTLY

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

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

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

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

SURVEY OF COUNCIL USE OF GLYPHOSATE

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

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

THERE ARE KNOWN HEALTH RISKS FROM GLYPHOSATE

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

We provide evidence of these risks our submission document.

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

We urge the government to take a strict precautionary approach.

GLYPHOSATE USE LEADS TO INCREASING HERBICIDE RESISTANCE

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

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

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

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

ECONOMIC RISKS OF GLYPHOSATE-BASED HERBICIDES

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

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

SOIL & HEALTH’S GLYPHOSATE PETITION

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

Supporters of our petition are calling on the government to:

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

OUR FULL SUBMISSION

Included in our submission are

Bayer Fails to Overturn European Ban on Bee-Harming Pesticides

The European Union’s highest court has rejected Bayer’s bid to overturn a European law which heavily restricted the use of bee-harming pesticides. In 2013 the European Union banned neonicotinoid, or ‘neonic’ use on bee-attractive crops. In 2018 the ban was extended to use on all outdoor crops, including annual arable crops, cereals and horticultural crops.

The General Court decision, released Thursday, is welcomed by the Soil & Health Association. This decision follows a prior bid by Bayer and Syngenta which had also failed to overturn the law.

The regulation relates to the ‘neonic’ insecticides clothianidin, thiamethoxam or imidacloprid; and applies to foliar sprays, soil treatments or seed treatments traditionally used in the growing period following winter.

Bayer’s appeal primarily argued that the European Union had not applied the precautionary principle properly and should have instead, engaged in a comprehensive risk assessment.

The precautionary principle is used when science has identified that an activity produces potentially dangerous effects, but where uncertainty remains about the extent of the risk.

The General Court of the European Union rejected Bayer’s argument, stating that an ‘exhaustive risk assessment cannot be required in a situation where the precautionary principle is applied, which equates to a situation in which there is scientific uncertainty’.

The Soil and Health spokesperson for pesticides, Jodie Bruning stated ‘This is an important finding. When we have technologies such as pesticides, interacting with environmental or human health, the decisions we take must very often be precautionary. Harm that results in death, or the dying out of a species often occurs as a result of multiple indirect effects. For honeybees, pesticides and environmental stressors interact. Over time this harm adds up to reduce resilience, causing honeybee deaths. 

‘The precautionary principle is important, because there is very rarely a single ‘smoking gun’ which can be traced and then blamed, for bee die-offs or colony collapse. We know that these insecticides last a long time in soil and water. We know they harm baby bee development, and impair flight as well as navigation. We can see that neonics reduce the capacity for bees to protect themselves from pathogenic viruses and the varroa mite.’

‘Recent testing shows we have concerningly high levels of neonics in New Zealand soils. We don’t have scientists paid long-term to research the health effects of neonics, so we don’t have scientists who can inform policy. Our farmers are buying unlabelled seeds, even for flowering clover. Farmers and orchardists do not know that the treatments they use are banned for outdoor use in the European Union.’

‘Because our scientists lack a mandate to research both human and environmental health effects, and the New Zealand Environmental Protection Authority relies on industry data to make safety claims, we have no authoritative expertise here. We are completely out of touch with best European practice.’

‘While the precautionary principle is only weakly applied in New Zealand, yet it has become a very important tool used by the European Union to protect environmental and human health.’

Japanese glyphosate scare highlights lack of regulation in New Zealand

A blasé approach to glyphosate regulation in New Zealand threatens our international reputation and poses a risk to New Zealand consumers, Soil & Health Association spokesperson Jodie Bruning said today.

“Japanese authorities have now rejected five shipments of glyphosate-contaminated honey from New Zealand’.

“New Zealand needs to take glyphosate contamination seriously. The International Agency for Cancer has recognised glyphosate as a probable carcinogen. Bayer, the producer of Roundup, has already paid over NZ$15 billion NZD to nearly 100,000 individuals around the world who developed cancer after being exposed to glyphosate-based herbicides.

“We support Apiculture New Zealand’s call to have a national conversation.

‘We believe the New Zealand government can adopt a more nuanced approach to glyphosate. This is not an all or nothing conversation. Farmers can still have access, but glyphosate can be more cautiously regulated to ensure premium exporters don’t get nasty surprises like the honey exporters have received with these rejected shipments.

Controls have been placed on honey exporters by MPI following Japan’s announcement that glyphosate residue had been found above the allowable limit. Jodie Bruning says these controls are necessary, but continue to place the burden of responsibility on the honey industry.

“It’s not the beekeepers or honey industry’s fault that glyphosate regulation in New Zealand is so poor.

“We don’t have prudent controls on the use of glyphosate in New Zealand and it’s time we realised that consumers who care about food, care that it is not contaminated with a probable carcinogen.

“Glyphosate is a contaminant and a health risk. Whatever we do to protect our export markets will ultimately protect our freshwater, our soils and our families.

Climate Commission draft advice to government, Autumn 2021

Summary of our submission

In general we support the spirit of this first Climate Change Commission (CCC) report, but we want strong and decisive action, and we want it more quickly than the report recommends. We think that the Commission’s proposed budgets need to be substantially enhanced to create greater emissions reductions over the next decade, to better align with efforts to keep global warming to 1.5 degrees.

The solutions lie before us, and we cannot delay any longer.

Our full submission

Download our full submission (PDF)

Concerns remain on improved Organic Products Bill 

Concerns for the future of New Zealand’s domestic organic industry have dampened enthusiasm for the Organic Products Bill which returned from Select Committee with some significant and useful changes, says the Soil & Health Association.

“We represent the thousands of people buying, growing and selling organic products,” says Soil & Health’s general manager Pete Huggins.

“This bill will be a huge step forward for organics in New Zealand and it’s vital we get it right. Consumers, producers and retailers all want a robust system of organic verification that drives confidence and growth in organics.

“We don’t think the verification regime being imposed by MPI is the correct one. This was not the scheme we were consulted on and isn’t our preferred option. It poses risks around cost increases that the domestic industry will struggle to bear. We think MPI have misunderstood what is required here, and are failing to listen to feedback.

“We know the whole organic sector is committed to working with the government to make this Bill the best it can be. At the moment our main concern is to nurture and enhance the domestic industry under this new regime. It would be a tragedy if the incoming regulation hampered efforts to grow food more sustainably.

“Organics is booming internationally, and our export sector should thrive under this new system. But we need to see assurances that the domestic industry will be supported and not undermined through increased cost and bureaucracy.

“The Select Commitee has already improved the bill significantly and we look forward to engaging with the government further.”

Climate advice means government should support transition to organic, regenerative farming

Today’s Climate Commission advice shows we need a transition from synthetic fertilisers and other harmful practices towards organic and regenerative agriculture, said Soil & Health Association spokesperson Jenny Lux today.

“Organic regenerative farming is a huge opportunity for New Zealand, both economically and environmentally. Early movers have shown that we can make that shift rapidly. With government help the transition to producing high quality, high value food within planetary limits is achievable for most NZ farms.

“We’d like to see funding and other support for farmers to start shifting to lower emissions agriculture now.

“The Climate Commission says we can tackle agricultural emissions with the technology we already have. This includes organic and regenerative practices like phasing out synthetic fertilisers, reducing tillage, and intensifying cover cropping to build soil health and promote biodiversity.

“Healthy agricultural soils sequester carbon. The government could drive this change with a policy to support farmers with technical knowledge and the costs of transition.

“Money in this year’s budget would be good.”

2020 AGM of the Soil & Health Association

Read the minutes and review reports presented to our 2021 Annual General Meeting.

Green Party organics policy adds vital ingredient to national debate on the environment

“It’s encouraging to see the Green Party reinforce their commitment to organic agriculture from their position in government,” says Jenny Lux, spokesperson for the Soil & Health Association, New Zealand’s largest organic membership organisation.

“We’d like to see all political parties exploring the opportunities regenerative organic agriculture offers in terms of environmental protection, healthy food, and resilient communities.

“We think the Green Party’s policy of creating a New Zealand sustainable food certification could finally help us meet our ‘100% Pure’ aspiration as a nation.

“However, a national accreditation would only work if it was based on measuring outcomes and met the standards for regenerative organic agriculture already recognised worldwide

“We also welcome the policy of capital investment and other support for growers wanting to transition to regenerative organic. The setup costs are often a major barrier to changing farming systems.

“Organics already earns export dollars at the same time as contributing to our Zero Carbon Act goals. Providing government funding for the organic industry and boosting funding for organic research and development is key to the future of this booming sector.

“At a time when people – consumers and growers alike – are increasingly concerned about health and environmental protection, it makes sense to be investing this way.”

Soil4Climate breaks new ground in Wellington

Sifting through soil for evidence of lifeWords by Marion Wood, Chairperson, Soil & Health Association of Aotearoa New Zealand
 
Did you know there’s triple the amount of carbon in soil worldwide as there is in the atmosphere? This was one of many ‘wow’ moments from the launch of Soil4Climate during Organic Week 2020.
 

About Soil4Climate

Soil4Climate will do several things at once. It will put carbon from the air back into the soil, support growth in biodiversity, reduce food miles, and build the food resilience of local communities.
 
But that’s not all. Soil4Climate will also support the wider community of enthusiastic growers. As a result, growers will gather data about what works, spread the knowledge of how to build soil health, and improve our methods of doing so.
 
This is an open collaborative piece of work that we hope will inspire many.
 

Jessica Barnes and Jenny Lux mixing soil samples at the Soil4Climate launch.

We’re excited to be underway at two sites. We have begun at Tapu-te-ranga marae in Island Bay and at For the Better Good’s Porirua ‘Edible Earth’ farm (in partnership with WELLFed). We’ve started by bench-marking the current health of the soil at both sites. Over the coming year we will watch as the soil is built up through organic growing methods.

Next we are going to grow the project to include test sites around Aotearoa. This will include urban farms, market gardens, pastoral land, schools and backyard gardens.

You can read a bit more about Soil4Climate here.

We firmly believe that organic growing methods are crucial to mitigating climate change.
 

So how does it work?

Our measurements follow established soil science methods

Our measurements follow established soil science methods

 

We’re using three sets of measurements to test for carbon and other nutrients in soil health:

  1. The Visual Soil Assessment – which is a hands-on observation of different aspects of the soil. We record how the soil looks, its colour, smell,  structure and even the number of earthworms – that bit was great fun!
  2. The soil Microbiometer – here we are measuring the microscopic life in the soil. We know this is vital for plant health and biodiversity. We are looking at microbial and fungal biomass, and working out the fungal to bacteria ratio.
  3. Laboratory analysis of soil content – we send samples to recognized laboratories who analyse the soil. We are measuring things like mineral elements and the carbon content.

Soil4Climate’s initial results will be compared with repeat tests done over time. We expect soil health to improve as we grow on the land and change it’s soil composition through organics.

At the same time we are supporting community growers to connect with each other. This project will support us all to learn new things. And of course we are growing nutritious healthy local kai to sustain community.

Jessica Barnes shows us the composting system at For the Better Good's Porirua 'Edible Earth' farm in partnership with WELLfed.

Jessica Barnes shows us the composting system at For the Better Good’s Porirua ‘Edible Earth’ farm in partnership with WELLfed.

How much impact can we have on carbon emissions?

There’s a perception that agricultural soils in Aotearoa can’t sequester carbon. We think this is because the soils that have been examined are mostly microbially impoverished soils. This means the microscopic life like bacteria and fungi have been destroyed. Chemical spraying, tillage, and other land practises are often to blame for this. It means the soils are not functioning naturally or optimally. 
 
For example, regenerative soil consultant Phyllis Tichinin estimates that 1-3 tonnes of carbon can be sequestered per hectare of pasture per year.  If this is the case then the pastoral sector alone could make Aotearoa carbon neutral (and even carbon negative) within just a few years. This can happen if we move powerfully now to adopt organic and regenerative practices.
 
We desperately need more research into this area. Soil4Climate is putting a stake in the ground – literally – to start this process.

Soil & Health launches glyphosate campaign

The Soil and Health Association are calling for councils to stop spraying glyphosate to keep New Zealand families safe.

‘The public increasingly understand that it is no longer acceptable to be exposed to glyphosate-based herbicides,’ says Soil & Health spokesperson Jodie Bruning,

We are working with US based Non-Toxic Neighbourhoods who have had significant success helping councils transition affordably to non-toxic urban management.

The importance of glyphosate science

Public health scientists think it is bizarre that the findings of the most prestigious cancer agency in the world were rejected by New Zealand’s Environmental Protection Authority (the EPA).

The International Agency for Research on Cancer (IARC) determined that glyphosate probably causes cancer in humans. The IARC also found that glyphosate (and it’s commercial formulations) definitely causes cancer in laboratory animals – placing our pets at risk too.

 In 2016 the EPA produced what scientists consider to be a flawed cancer review to discredit the findings of the EPA’s own cancer authority.  New Zealand professors and scientists remain ‘mystified’ and have spoken repeatedly (here and here and here) about the EPA’s frozen stance on glyphosate. An Official Information [ENQ-35127-N5J6C7]request has found that the EPA has never conducted a formal risk assessment of glyphosate or the commercial formulation.

Glyphosate is not just a cancer risk. Scientific studies show that glyphosate-based herbicides, including Roundup, may not only probably cause cancer but cause oxidative stress and disrupt endocrine system function which can set the stage for disease and delays.

Chemical companies are paying out for the damage caused

Following the IARC decision, cases in the U.S. have awarded the claimants damages against Monsanto (since 2018, owned by Bayer). The court cases uncovered evidence that showed how Monsanto took action to limit and distort public knowledge. Punitive damages were awarded for ‘reprehensible’ conduct. The jury trials are now under appeal with Bayer claiming the verdict of regulators across the world upholds Bayer’s stance. Unfortunately, as scientists have illustrated (in Europe and the USA), regulatory agencies relied on ghostwritten industry studies and ignored data that the IARC considered important.

In June 2020 Bayer proposed a settlement of USD$8.8-10.9 billion to settle over 125,000 U.S. lawsuits to resolve Roundup litigation. Bayer has framed the complex settlement proposal as an end to ‘uncertainty’. The proposal contained no admission that glyphosate-based herbicides caused the cancer claimed by cancer sufferers, many former farmers, who see the proposal as a slap in the face. The settlement proposal may restrict future claimants from a jury trial. New Zealand doesn’t face the same court cases here because the ACC covers such cases as accidents.

Why isn’t New Zealand taking action?

Ignoring the calls of scientists, New Zealand councils refer to the New Zealand Environmental Protection Authority (NZ EPA) to claim that glyphosate is a ‘low toxicity herbicide’. The hazard rating given by the NZ EPA provides a legal rationale that it is safe enough to spray in public places. This is wrong!

It is evident from operations in Auckland and Christchurch that councils and contractors need to make a lot of changes in order to shift away from glyphosate dependency – like any addiction – shifting to a new mindset isn’t always easy. Much of the management and contract negotiation are out of the public eye – so it is difficult for the public to understand what is going on. Councils don’t appear to be undertaking properly accountable trials with new technologies and recording and documenting trial methods, how they cope with and reduce over time the weed seed banks, and making this information public. We know non-toxic alternatives and management regimes can never neatly replace toxic chemical use. Shift away from addiction requires a change in mindset and operations.

We also understand that councils struggle to adopt the precautionary principle. This would help deal with uncertainty (which is always present). Councils may not be comfortable weighing the risk to families, and particularly babies and children, with the risk of complaints from irate rate-payers or staff worried about the stress on physical assets. These are value-based decisions, and are an important part of making any decision to protect health or the environment.