Submission to the FSANZ
Application A1186 Soy Leghemoglobin
February 13, 2020
FSANZ Supporting documents can be found here
A successful approval of A1186 Soy Leghemoglobin by FSANZ will result in the release of Impossible Foods burgers and associated products onto the New Zealand market for consumption by the product. Much of this product would be sold through take-away outlets and restaurants and in this form, would remain unlabelled.
Soil and Health consider that the application for A1186 Soy Leghemoglobin which is a mixture referred to as ‘LegH Prep’ is inadequate to ensure a high standard of public health protection. Much of the documentation and marketing of Impossible Foods products infer that these products are substantially equivalent to unprocessed meat, and represent a safe and healthy vegetarian protein option.
We consider that regulatory activities which fail to consider the implications of release of an ultra-processed, high salt, genetically modified soy protein product on the market – and regulatory treatment of this product as substantially equivalent to healthy, grass raised beef or lamb, or home-made vegetarian burgers made from non-genetically modified vegetable proteins, may be misleading.
Therefore the Soil & Health Association of New Zealand consider that the current application and approval process does not contain sufficient information to ensure activities relevant to the approval will fulfill the Objectives of the Food Standards Australia New Zealand Act 1991. We note:
1.1. The report ignores the health impact of the final product. The LegH Prep has been specifically developed to be an ingredient in an ultra-processed convenience food product.
1.2. Nutrition is cherry-picked despite the product being positioned as a meat substitute. Equivalent iron is not substantially equivalent as other nutritional parameters are ignored in the application.
1.3. The contaminant profile 2 from herbicides contained in the retail product, which unprocessed meat does not contain has been ignored.
1.4. Differing health effects relating to the potential for endocrine disruption at different life stages has been ignored.
1.5. There are no long-term dietary studies – a 28-day study restricts consideration on health effect and the longer dietary studies are reasonable to scientifically risk assess long term (chronic) effects.
1.6. The chronic toxicological parameters relating to immunotoxicity, carcinogenicity, oxidative stress, as well as endocrinological effects are not clearly published.
1.7. 90-days dietary study must be supplied, including endocrinological test results, for the risk assessment to be scientifically appropriate to assess health risk:
– OECD Test Guideline (TG) 408 – repeated dose 90-day oral toxicity study – (Updated in 2018)
1.8. Due to the scientific knowledge gaps and the deficiencies, and with particularly consideration of the commercial outcome of the approval of LegH Prep – the potential for a commercial product that the applicant intends to be considered a staple dietary product in the New Zealand and Australian diet – the Soil and Health Association of New Zealand propose that the LegH Prep (A1186) application should be declined.
In addition, the attached PDF which formed the content of our submission to the FSANZ discussed the following issues:
2.0 Precautionary Principle.
3.0 Soil and Health note that section 18
4.0 Food Standards Australia New Zealand Act Section 18.
5.0 Endocrine gaps and gender specific health effects.
6.0 Ultra-processed convenience food.
7.0 90-day dietary studies should study the formulated retail product.
8.0 Contaminants from dietary exposure.
9.0 Misleading cost-benefit analysis.
10.0 Misleading: Substantial Equivalence.
11.0 Misleading: Greater toxicity of the formulation
12.0 Misleading: Scientific knowledge gaps
Climate Commission draft advice to government, Autumn 2021
/in SubmissionsSummary 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
/in Farming, Food, Media Releases, OrganicsConcerns 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
/in Campaigns, Farming, Media Releases, Organics, Soil4ClimateToday’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
/in Association Meetings and EventsRead 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
/in Farming, Food, Media Releases, Organics, Water“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
/in Soil4ClimateAbout Soil4Climate
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.
So how does it work?
Our measurements follow established soil science methods
We’re using three sets of measurements to test for carbon and other nutrients in soil health:
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.
How much impact can we have on carbon emissions?
Soil & Health launches glyphosate campaign
/in Campaigns, GlyphosateThe 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.
Kiwis exposed to health risks from weedkiller
/in Glyphosate, Media ReleasesThe Soil & Health Association has welcomed Bayer’s announcement of US$10 billion in payouts to tens of thousands of claimants in the US who allege exposure to Roundup herbicide caused their cancer.
“But here in New Zealand, we have an untenable situation where glyphosate-based herbicides are sprayed broadly in urban environments, and on human food and animal feed crops,” said Soil & Health Association spokesperson Jodie Bruning.
In 2018 Soil & Health applauded Christchurch City Council for its decision to stop glyphosate use in public spaces, but now the Association is concerned that the Council is considering a possible reversal of that decision for budgetary reasons, and may choose to rely on the Environmental Protection Authority (EPA) for a glyphosate safety tick.
However, an Official Information Act request revealed that the EPA has never conducted a risk assessment of glyphosate, nor the more toxic formulations used in New Zealand.
“For the most commonly used herbicide in New Zealand, this is really quite astonishing. We have no idea how it persists in our own environment. As a result, much of the scientific data cited by the public in presentations to councils has simply never been considered by our hazardous chemicals regulator,” Jodie Bruning said.
Soil & Health is concerned with uncontrollable public exposure and the risk farmers, council applicators and contractors face.
“The public cannot avoid urban sprays. We don’t know how long glyphosate lasts, because there is no testing in the streets where our kids walk to school.
“The lack of EPA stewardship leaves regional and local councils divided. On one hand, they defer to the EPA’s claim that glyphosate is ‘considered safe’ when managed appropriately. On the other hand, they are hearing from a well-informed public about all the data the EPA has never considered, because it continues to rely on reauthorisations containing data selected and supplied by the chemical industry.
“It’s time this biased approach to chemical regulation was put to bed, and the EPA realised that weak regulations only serve the industry that they’re supposed to be regulating.
While calling for the use of glyphosate to be banned from public places, Soil & Health acknowledges the difficulty for farmers shifting away from using glyphosate to prepare paddocks prior to planting.
“Certified organic farmers successfully farm without glyphosate, and Soil & Health calls for more funding into research, education and farmer extension to expand the use of safe, herbicide-free organic methods of farming,” said Bruning.
The Organic Products Bill
/in SubmissionsSummary of our submission
The Soil & Health Association is focused on the following 10 points:
Our full submission
Download our full submission (PDF)
A1186 Soy Leghemoglobin (Impossible Foods)
/in SubmissionsSubmission to the FSANZ
Application A1186 Soy Leghemoglobin
February 13, 2020
FSANZ Supporting documents can be found here
A successful approval of A1186 Soy Leghemoglobin by FSANZ will result in the release of Impossible Foods burgers and associated products onto the New Zealand market for consumption by the product. Much of this product would be sold through take-away outlets and restaurants and in this form, would remain unlabelled.
Soil and Health consider that the application for A1186 Soy Leghemoglobin which is a mixture referred to as ‘LegH Prep’ is inadequate to ensure a high standard of public health protection. Much of the documentation and marketing of Impossible Foods products infer that these products are substantially equivalent to unprocessed meat, and represent a safe and healthy vegetarian protein option.
We consider that regulatory activities which fail to consider the implications of release of an ultra-processed, high salt, genetically modified soy protein product on the market – and regulatory treatment of this product as substantially equivalent to healthy, grass raised beef or lamb, or home-made vegetarian burgers made from non-genetically modified vegetable proteins, may be misleading.
Therefore the Soil & Health Association of New Zealand consider that the current application and approval process does not contain sufficient information to ensure activities relevant to the approval will fulfill the Objectives of the Food Standards Australia New Zealand Act 1991. We note:
1.1. The report ignores the health impact of the final product. The LegH Prep has been specifically developed to be an ingredient in an ultra-processed convenience food product.
1.2. Nutrition is cherry-picked despite the product being positioned as a meat substitute. Equivalent iron is not substantially equivalent as other nutritional parameters are ignored in the application.
1.3. The contaminant profile 2 from herbicides contained in the retail product, which unprocessed meat does not contain has been ignored.
1.4. Differing health effects relating to the potential for endocrine disruption at different life stages has been ignored.
1.5. There are no long-term dietary studies – a 28-day study restricts consideration on health effect and the longer dietary studies are reasonable to scientifically risk assess long term (chronic) effects.
1.6. The chronic toxicological parameters relating to immunotoxicity, carcinogenicity, oxidative stress, as well as endocrinological effects are not clearly published.
1.7. 90-days dietary study must be supplied, including endocrinological test results, for the risk assessment to be scientifically appropriate to assess health risk:
– OECD Test Guideline (TG) 408 – repeated dose 90-day oral toxicity study – (Updated in 2018)
1.8. Due to the scientific knowledge gaps and the deficiencies, and with particularly consideration of the commercial outcome of the approval of LegH Prep – the potential for a commercial product that the applicant intends to be considered a staple dietary product in the New Zealand and Australian diet – the Soil and Health Association of New Zealand propose that the LegH Prep (A1186) application should be declined.
In addition, the attached PDF which formed the content of our submission to the FSANZ discussed the following issues:
2.0 Precautionary Principle.
3.0 Soil and Health note that section 18
4.0 Food Standards Australia New Zealand Act Section 18.
5.0 Endocrine gaps and gender specific health effects.
6.0 Ultra-processed convenience food.
7.0 90-day dietary studies should study the formulated retail product.
8.0 Contaminants from dietary exposure.
9.0 Misleading cost-benefit analysis.
10.0 Misleading: Substantial Equivalence.
11.0 Misleading: Greater toxicity of the formulation
12.0 Misleading: Scientific knowledge gaps