Submission to urge the New Zealand government to put in place regulations for zero tolerance for pesticides in baby food

Petition of Alison White and 4276 others. 
Submission by Alison White and Dr Meriel Watts.
Presented by: Mojo Mathers
Referred to: Primary Production Committee.
Date presented 29 May 2014

Following transcription from original submission in parliament.

Petition 2011/112 House of Representatives urge the government to put in place regulations for zero tolerance for pesticides in baby food; specifically that New Zealand match the European Union Directives [1] that processed infant and young children’s food must not contain pesticide residues greater than 0.01ppm (mg/kg).  

Submission by Alison White of Safe Food Campaign:

We've got more than 4,200 people who signed this petition. A common reaction from people was that of course we don't want pesticides in baby food. I'm surprised that they're there anyway. So that was a very common reaction we found when we asked people if they were interested in signing the petition.

In my written submission I gave references to support the fact that different countries around the world, different regulatory authorities have made a special provision for children in regard to pesticide residues in food and baby food in particular. The European Union which is the model that has led the way on this has certain directives which are detailed in the submission with a basic policy of zero tolerance for pesticide residues in food. This is what we want to encourage this select committee to think about doing for New Zealand so we can do this and better protect Kiwi babies. We believe Kiwi babies deserve the same protection as European babies for example.

We would like to draw your attention to this rather startling information. If we compare EU surveys of baby food, We find over 2000 samples in the EC - .04% have pesticide residues – contrast that to NZ in the last survey published 2009, 31.3% have pesticide residues, this is an enormous difference, nearly 800 times more pesticide residues here in NZ.
We’d like some things to be done.

Apart from NZ following EU directives, is to do more regular and more extensive surveys of baby food. At the moment we have baby food surveys that are part of the total diet surveys every 5 or 6 years, the last one in done 2009, that was not nearly enough.  They had only 8 samples in 4 different categories of food processed in NZ.

That is not nearly enough. We need to establish a baseline to act from and to compare internationally. 

Submission by Dr Meriel Watts, presenting on behalf of Pesticide Action Network.

Why are children so much more vulnerable to pesticides than we are ourselves?

MRLs that are set for our foods are based on adult tolerances and do not automatically protect children.  In many ways they don’t protect them at all. Children consume much more relative to bodyweight.  Therefore their intake of pesticides relative to adults is much greater. Water is 7 times more, … would be a similar level to food. This at a time when they are particularly vulnerable. When MRLs are set they are only based on one pesticides in that food, and do not look at other avenues of exposure. This can result in much greater exposure. From, air, hand to mouth, those ways results in much greater exposure.

Today babys are born pre-polluted. Mothers who are exposed to pesticides pass it across the placenta. It’s found commonly in placental cord blood, amniotic fluid, in the foetus itself and in the foetus first born faeces. 46 different pesticides are measured in the first borns’ faeces of children. 

When MRLs are set they are only based on one pesticides in that food, do not look at other avenues of exposure. This can result in much greater exposure. From, air, hand to mouth, those ways results in much greater exposure.

They carry a load of pesticides before they hit the world. This is not taken into account when MRLs for food are set.

We have a situation where a lot of these pesticides have additive or synergistic effect – you add one more pesticide the total effect increases.. this is not looked at when the MRL is set.
We are totally underestimating the amount of exposure children have.

What’s really critical is the vulnerability of small children. The developing foetus and newborns – all of their body systems are still in the process of developing, at this stage, particularly the brain and the immune system. During that development process they are acutely, exquisitely sensitive to interference from minute levels of pesticides. This process of development is also not taken into account when MRLs are set for food.

If a child is exposed to an endocrine disrupting chemical at this point it can affect their development for the rest of their lives but also down subsequent generations.

I want to draw your attention to pesticide chlorpyrifos. NZ children are exposed to 100 times more residues of this than for example Japanese children. We know chlorpyrifos is found in a number of our foods. We know from US studies, 4.6 picograms in the cord blood – a tiny amount – far below what we measure in our residue monitoring, 4.6 picogram in the cord blood going through to the developing child is enough to lower their IQ and working memory. 4.6 picograms is 400 million times less than the levels that have been found in our food supply.

Of course not all this is absorbed, and will end up in the brain but a substantial amount is because chlorpyrifos is readily and widely absorbed by humans. I use this just as an illustration – many other pesticides are also found at higher levels in our food and can impact children’s brains and other developing organ systems.

In conclusion, in my book and in my submission I have stated internationally accepted evidence based reasons for why children are very much more vulnerable to pesticides and why they are so much more exposed than we are.  I have illustrated this with just one chemical, chlorpyrifos. Children are exposed to a huge number of chemicals including pesticides on a daily basis …all of which can interact with each other and undermine their ability to contribute to society productively.

Any decrease of IQ in children shifts the whole spectrum of intelligence in society towards the lower end. It means we end up with a huge increase in the number of people who are intellectually challenged and a huge decrease in the number of people who are gifted.
This has a major impact in our society and our ability to get ahead in the world as a country.
This has a big impact on our social systems, because one of the things that goes hand in hand with this is an increase in crime statistics, an increase in suicides, and an increase in difficulties in socialising, as well as of course increases in health problems.

All of which have a huge impact in cost to our society including the health system. So it seems to me it is entirely reasonable to ask that we have zero residues of pesticides in baby food.

I noted a letter in the paper this morning.. a letter..  the government is spending quite a lot of money to subsidise the production of apples with zero residues in the Japanese market. Why can’t we do something to regulate for zero residues. Surely we care about the residues in baby’s food more than we care about residues in the Japanese market.


The conclusion of the Committee can be found here:

Petition 2011/112 of Alison White and 4,276 others. NZ House of Representatives  Report of the Primary Production Committee


[1] COMMISSION DIRECTIVE 2006/141/EC of 22 December 2006 on infant formulae and follow-on formulae and amending Directive 1999/21/EC.  Article 10
1.   Infant formulae and follow-on formulae shall not contain residues of individual pesticides at levels exceeding 0,01 mg/kg of the product as proposed ready for consumption or as reconstituted according to the instructions of the manufacturer.

Poisoning our Future: Children and Pesticides. Dr Meriel Watts. Pesticides Action Network.

Chlorpyrifos as a possible global POP. Meriel Watts PhD. For Pesticide Action Network North America.  August 2012.