NZ EPA slipping away from European safety standards

New Zealand pesticide (including herbicides, miticides, insecticides, fungicides, fumigants) food safety is slowly but surely slipping away from European standards. This is problematic as New Zealand farmers and producers are proud of the products they produce. Erosion of reputation happens slowly. Food quality in 2018 is as dependent on chemical hygiene as it is on microbiological hygiene. That’s where the premium market sits, and there is no avoiding this fact.

New Zealanders - producers and civil society - depend on an independent (unbiased) flow of information and sound evidence based science. This is how risk is transparently addressed. We need to understand both environmental exposures and risk based on what the published scientific literature is revealing.

 FAO data from http://www.fao.org as at November 2018

FAO data from http://www.fao.org as at November 2018

Problem No.1.

New Zealand regulators traditionally kept records of pesticide volumes so that pressure on the environment could be assessed. This is no longer happening. Statistics showing breakdown into herbicide/insecticide/fungicide etc categories had been supplied to the FAOSTAT database. This appears to have stopped in 2009. Until 2009 usage had been increasing. The last tonnage recorded was 5086 which continues as the quantity recorded until the last entry-point of 2016.

In 2009 pesticide categories data breaks down into herbicides (2914); Insecticides (303) and fungicides/bactericides (1296). Respectively as a percentage herbicides form 57% of pesticides applied in New Zealand, fungicides/bactericides 25% and insecticides (that are not used as seed treatments on arable crops) 5%. The database has the capacity to represent seed treatments (as fungicides and insecticides) but New Zealand data does not appear to be supplied. Of course, European regulators keep data on European sales.

Herbicides are the most used pesticide in the New Zealand landscape and glyphosate is the most used herbicide. Glyphosate formulations are frequently applied with metsulfuron-methyl and organosilicon surfactants . (Neither of these co-applied chemicals are tested in the New Zealand environment.) Every company keeps data and there are limited competitors in the market, if regulators wanted to keep tabs, they could.

Problem No. 2

The NZ EPA has recently produced a NZ EPA Priority Chemicals List. The previous Chief Executive-initiated reassessment List which considered ubiquity in the environment has disappeared.

A new tool to consider what chemicals most require assessment and inclusion on this Priority Chemicals List has been invented - FRCaST. This tool is not used anywhere else in the world. EPA claim ‘Our work with international partners to peer-review our approach demonstrates our approach is in line with internationally accepted practices.’ Well no. EPA asked buddies Australia and Canada and they listed a bunch of uncertainties. FRCaST doesn’t appear to require the NZ EPA to conduct a transparent review of recently released science of published literature (as new data) to evaluate whether a substance poses greater risk to the public and the environment than previously thought. I have emailed an OIA request to confirm this. So is our chemical regulator only using data it already has, which is predominantly supplied by the chemical industry, to decide if it should do a risk assessment?

Does this mean that NZ EPA is restricting itself in its consideration - and is biased?

NZ EPA also doesn’t appear to prioritise based on ubiquity in the environment – because, well, oops, we don’t know because data stopped in 2009, as discussed. The old Chief Executive-initiated reassessments list (CEIR) list which considered degree of exposure has been disappeared. The new FRCaST tool appears to have no capacity to assess exposures and risk to farmers/applicators and infants and children from diet or environment.

Glyphosate was on the old CEIR list but has been disappeared off the new list.

To the skeptical mind, FRCaST may appear to be a tool of prevarication. There is a lot of money and power behind keeping a profitable herbicide like glyphosate on the market. On the market does not just mean as a herbicide to spray down weeds for no-till agriculture and arable cropping. If the science can be avoided, this will keep the probably carcinogenic solution being sprayed down every roadside (in my region, 3-4 times a year) - (despite growing herbicide resistance that has the impact to damage food production); it will keep it being sprayed on New Zealand grown cereals, pulses and lupins (despite the fact that pre-herbicide sprays are the main route of exposure for city people). It also avoids addressing deeply worrying issues of antibiotic resistance (or antimicrobial resistance).

Besides, the New Zealand chemical industry lobby group - AgCarm would be grumpy if glyphosate were restricted to just the people who really need it (no-till arable crop producers who don’t use it as a pre-harvest dressing).

39 chemicals as at November 2018 are listed on the NZ EPA Priority Chemicals List:

A quick search on the EU Pesticides Database confirms whether the thirty-five pesticides listed on the Priority List are approved, or not, for use in Europe. Nineteen (19/35) are not approved for use:

Not approved: Alachlor, amitrole, Bioresmethrin, Brodifacoum, Carbaryl, Carbendazim, Cyfluthrin, Cyhalothrin, Diazinon, Dichlobenil, Dichlorvos, Fenitrothion, Fenthion, Flocoumafen, Paraquat, Propargite, Propoxur, Trifluralin.

Some are approved but related chemicals may not be:

Approved: 2,4-DB (2032), alpha-Cypermethrin (2019); Bifenthrin, Chlorpyrifos (2019),  Cypermethrin (2019), Cyproconazole (2021), Deltamethrin (2019), Diuron (2019), Flumioxazin (2019), Folpet (2019), Lambda-cyhalothrin (2023), Maldison/Malathion (2022), Oxadiazon (2018), Permethrin (2019), Pirimiphos methyl (2019),

Pending: Chloropicrin

Four of the thirty nine on the Priority List are not pesticides: 4,4'-(1-Methylethylidene)bis[2,6-dibromophenol] (TBBPA) (CAS 79-94-7) ; Ammonium pentadecafluorooctanoate (APFO) (3825-26-1) , Benzo[a]pyrene (50-32-8), Tributyltin oxide (56-35-9). (50-32-8 and 3825-26-1 are included on the EU substances Candidate List of substances of very high concern )

Finally, these aren’t on the list but should be:

Not approved in the EU but in NZ groundwater: hexazinone

Not approved in the EU but highly controversial: methyl bromide

Chemical users depend on valid and transparent risk assessment. Farmers and pesticide contractors expect the NZ EPA to be looking at independent science and considering the toxicity of the full formulation to give them a fair chance at using a safe product. It’s not just for cancer, nor mental health. It’s inflammation, kidney, liver, eye health, and at levels lower than NZ EPA claims are safe - see the papers listed below.

Further reading on glyphosate formulations and toxicity:

[1] Myers J P et al (2016). Concerns over use of glyphosate-based herbicides and risks associated with exposures: a consensus statement. Environmental Health 15(19). DOI 10.1186/s12940-016-0117-0. https://ehjournal.biomedcentral.com/articles/10.1186/s12940-016-0117-0

[2] Douwes et al (2018) Carcinogenicity of ­glyphosate: why is ­New­ Zealand’s ­EPA­ lost in the weeds? NZMJ

[3] Vandenberg et al (2016) Is it time to reassess current safety standards for glyphosate-based herbicides? Epidemiology & Comm. Health.