2011 Letter to Councils and DHBs

1 February 2011

The CEOs and Councillors of all Regional, District and City Councils in New Zealand

The CEOs and Board Members of all District Health Boards

Long Term Council Community Plans 2011

PSGR’s Trustees thank Councils for their responses to our previous correspondence and ask that you please take into consideration the following when drawing up your Community Plans 2011.

Genetic engineering technology

We remind Councils of their need for the on-going monitoring of developments in genetic engineering technology and the potential impacts on their community and environment.

1. Transgenic animal experiments and waste disposal

AgResearch continues to operate using approved Applications made to the Environmental Risk Management Authority. How far it will experiment with organisms using a range of genetic modifications needs to be carefully monitored. It has proposed research involving many different animals and organisms, and a range of undeclared or unknown genetic constructs, for the general purpose of research, breeding and production of commercial products such as antigens, enzymes, biopharmaceuticals and hormones for commercial release.

Of relevance to all Councils is the fact that AgResearch contends that its current containment facilities are insufficient and it has proposed using centres for larger animal genera sited in either the North or South Islands that would be operational over indefinite periods of time. Containment may simply mean fencing.

PSGR contends that AgResearch has failed to adequately meet relevant sections of HSNO legislation and therefore the basis of ERMA’s statutory obligations under the HSNO Act, and that deliberate exclusion of information has excluded ERMA from basic material to enable it to determine and evaluate risks to public health from transgenic livestock maintained or produced as a consequence of its experiments. Realistic assessment of transgenic constructs in terms of risk probability is impossible.

Of immediate concern is the handling of experimental stock at sites where public disclosure is not made: for example, disposal of carcases and animal waste and their effect on soil organisms, and ground water and run off.

Councils should be especially aware of waste materials from transgenic livestock operations disposed of off-site; ‘off-site’ being taken to mean ‘not in containment’ under HSNO, and including undocumented geographic locations and, consequentially, unknown interactions with the receiving environments.

AgResearch’s activities need extremely close monitoring should they take place in your area.

For background information, we refer you to a PSGR submission to ERMA: www.psgr.org.nz/index.php?option=com_content&view=article&id=59:submission-to-erma-on-agresearch-applications-gmc07012-gmd07074-gmd08012-and-gmf07001&catid=24:environmental-risk-management&Itemid=39

2 Genetic engineering experiments with pinus radiata and terminator technology

The New Zealand Forest Research Institute Limited, trading as Scion, has received approval from the Environmental Research Management Authority (ERMA) to plant pinus radiata with a number of engineered traits, including herbicide-resistance: Applications GMF000032; GMF000033; GMF000034; GMF000035; GMF000036; GMF000037; GMF000038; GMF000039; all approved with controls.

See www.ermanz.govt.nz/find/WebResults.aspx?search=GMF99001+&submit.x=30&submit.y=16.

The trees would be trialled over two decades in the open environment in the Rotorua area. The premise is that the trees will largely be engineered using what is commonly termed ‘terminator’ technology, making the trees sterile, not able to flower or replicate.

Transgenic traits tend to be unstable and the variants of terminator technology offer no absolute guarantee of sterility. The traits can break down and the trees revert to flowering. Even if totally sterile, terminator trees can spread by asexual means. Genes can spread horizontally in soil bacteria, fungi and other organisms in the extensive root system of forest trees. There could be long term impacts on the soil biota and fertility. Sterile monocultures are known to yield more readily to disease.

Trees that do not flower and fruit cannot provide food for the organisms that feed on pollen, nectar, seed and fruit; thus, essential pollinating insects may not be available especially for beekeepers and horticulturalists.

One of the proposed engineered traits is herbicide-resistance. In the US, herbicide-tolerant transgenic crops have increased the use of herbicides, rather than cause a reduction in usage. This has led to substantial numbers of weed species becoming herbicide-resistant and in turn causing major difficulties for farmers other and growers.

New Zealand has a profitable forestry industry that has developed over 150 years using selective breeding. It is largely dependent on pinus radiata. It is a major export earner and a significant employer.

You may feel your area is too far away to worry about contamination or cross-pollination. In this, we refer you to Singh el al (1993) who found that pollen from pine trees had travelled over 600 kms. Many other studies have proven the ability of pollen to travel. Pollen is in the order of 100 to 10 microns or smaller in size. Once in the atmosphere, it can travel vast distances. It would need a failure rate of only a part of a percent for transgenes in pollen to contaminate other trees, potentially at great distances, in ways that could not easily be monitored.

The risk is both environmental and economic. Terminator technology has attracted a voluntary moratorium from most countries because of the risks involved. The effect on New Zealand’s reputation overseas and exports could be damaging. These experiments are not in New Zealand’s best interests.

We refer you to our full submission to the Environmental Risk Management Authority (ERMA) on this Application: www.psgr.org.nz/index.php?option=com_content&view=article&id=80:submission-on-application-erma200479-to-field-test-in-containment-pinus-radiata&catid=24:environmental-risk-management&Itemid=39.

ERMA’s decision: www.ermanz.govt.nz/find/WebResults.aspx?search=GMF99001+&submit.x=30&submit.y=16

Singh, G et. al., ‘Pollen-Rain from Vegetation of Northwest India,’ New Physiologist, 72, 1993, pp. 191-206.

Nanotechnology

In previous correspondence, we have drawn Council’s attention to the products of nanotechnology and the potential uncertainties about its waste products. We thank those Councils who enquired further.

Nanotechnology is used in food products and packaging, and cosmetic products like sun cream. It is used or proposed for items such as car windscreens and bumper bars, sports goods, paint, and clothing. It is used to produce some medical items. There are household ‘nano’ products on the New Zealand market. Here are just three:

Nanokote (www.nanokote.co.nz) for shower protection, applied by a tradesperson;

Easyclean Easyclean Shower and Glass Shield (www.nanonanonano.com.au), a self-applied shower protector, available at New World Supermarkets;

Whitewash Sponge (www.mitre10.co.nz/preview.cfm?mid=345&dept=14&subdept=119&item=325335), an inexpensive cleaning sponge available at stores like Mitre Ten and Bunnings.

Nanotechnology products have some risks and some potential advantages. PSGR is concerned with the lack of adequate safety testing and potential risks. We have trialled the Whitewash Sponge. It cleans brilliantly, but quickly disintegrates on use. Setting aside potential health issues faced during use, what happens to the remnants of the sponge when tossed into the rubbish bin? Councils and District Health Boards may find themselves dealing with the consequences.

Nanotechnololgy uses the building blocks of everything living and non-living; chemical elements. It operates at a scale of 100 nanometres (nm) or less. One nm is one billionth of a metre; the eye cannot see it. At this scale, the properties of a material can change, posing both advantages and difficulties.

The Ministry for Research, Science and Technology (MoRST) is reviewing the regulations. PSGR would like more details on safety tests being carried out; few have been made public.

Despite the vigilance of MoRST, PSGR believes New Zealand Councils and District Health Boards need to be accountable in their own districts and take a lead in the issue of dealing with nano waste. We refer you again to www.ci.berkley.ca.us/, enter nano waste in ‘search’ and we suggest you take a further step by opening communications with the City of Berkeley in California, the first body worldwide to address nano waste.

In terms of human health, a study published in the respected European Respiratory Journal (ERJ) looked at women workers exposed to nanoparticles in an inadequately vented workplace in China. Seven became seriously ill and two died. Autopsies found nanoparticles in the brains of the dead women. New Zealand regulations should prevent this, but we must bear in mind the size of the particles and the difficulties in controlling them.

We know that nanoparticles can pass through epithelial surfaces (skin, gastrointestinal, conjunctiva) and the endothelial barriers lining blood vessels. They can be inhaled and can pass through the blood-brain barrier. It is feasible that, over a period of time, the likes of a cleaning product that disintegrates on use could affect the user.

PSGR maintains that insufficient attention has been given to research on the safety or not of nanoparticles, especially on handling nano waste; e.g. the reduction and treatment of industrial and agricultural wastes, and ground water remediation. We do not know if nanoparticles persist and accumulate in the environment, and what may happen ecologically. We do not know if being absorbed by soil may reduce bioavailability or whether nanomaterials could harm soil bacteria, the engine of the ecosystem and food chain.

We ask District Health Boards to establish ways to safely handle medical products involving nanotechnology. We ask Councils to look at safe ways to handle the manufacturing, retail and domestic waste products of nanotechnology.

We refer you to:

Eur Respir J 2009; 34:559-567 doi: 10.1183/09031936.00178308, ‘Exposure to nanoparticles is related to pluerual effusion, pulmonary fibrosis and granuloma’, Y Song, X Li and X Du.

Submission to Tauranga City Council on nano waste: www.psgr.org.nz/index.php?option=com_content&view=article&id=81:submission-to-tauranga-city-council--western-bay-of-plenty-district-council-nano-waste&catid=21:general&Itemid=39

Tauranga City Council’s response: www.psgr.org.nz/index.php?option=com_content&view=article&id=83:response-to-submission-on-nanotechnology-waste-tcc&catid=21:general&Itemid=39.

PSGR ‘Science Watch’ page in Organic New Zealand on Nanotechnology (September/October 2010 Vol 69 No 5 and November/December 2010 Vol 69 No 6).

Depleted uranium

MP Phil Twyford is to present a private member’s Bill in Parliament to ban depleted uranium in New Zealand; the Depleted Uranium (Prohibition) Bill. Mr Twyford is Associate Foreign Affairs Spokesperson (Disarmament and Arms Control).

PSGR fully supports this Bill. However, we are cognisant of the necessary small quantity of depleted uranium used in medicine and science. We also acknowledge that some of this country’s military aircraft have depleted uranium trim weights on board. We understand the New Zealand Military have previously said they would not oppose the banning of depleted uranium.

Of concern, are the dangers presented by the presence of depleted uranium in the form of weapons or large quantities in storage.

In stable storage containers, there can be long-term risks for handlers. In the event of a leak, there would be immediate dangerous effects to staff and people living downwind of the facility, and the environment. In a country prone to earthquakes, we should be cognisant of the additional potential for serious accidents. Should government decide to have depleted uranium stored in New Zealand, we would potentially expose workers, local populations and the environment to radioactive contamination.

We ask Councils to establish a watching brief on developments.

We look forward to hearing from you of the steps you have taken to monitor and/or action the above concerns.

Trustees of Physicians and Scientists for Global Responsibility

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