2012 NZ Councils and DHBs

23 March 2012

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 2012 - 2022

The Trustees of PSGR thank Council for their response to previous correspondence and for keeping us informed of Council’s plans. We again ask that you take into consideration the following concerns for a sustainable district and a healthy community when establishing your Long Term Plan 2012-2022.

Genetic engineering technology

We remind Council of the need for on-going monitoring of developments in this technology and the potential impacts they may have on the well-being of your community and environment. See our letter of 1 February 2011: 1. Transgenic animal experiments and waste disposal; 2. Genetic engineering experiments with pinus radiata and terminator technology.

Of concern is the Ministry for the Environment proposing research focused on promoting more engineered organisms – potentially for release into the open environment. Promoting the greater use of transgenic organisms will challenge the New Zealand Brand and Clean Green image, and with TPPA conditions (see below) may weaken bio-security standards. Of particular concern to Council would be the sectors potentially being targeted to use these organisms: Pastoral farming; Horticultural; Aquaculture; Forestry; Waste.

A recent letter from the US Trade representative on the Trans Pacific Partnership Agreement (TPPA) negotiations said equivalency rules should “avoid the types of regulatory barriers that are increasingly among the key obstacles to trade”. We are rightly concerned that negotiations for the TPPA may compromise the Clean Green foundations of New Zealand's economy by acceding to acceptance of transgenic agricultural products, including seed, against the best interests of this country. In the past, MAF has destroyed seed contaminated with transgenes. Many of our export markets will not accept transgenic DNA in a product. Keeping NZ regulations strong is essential to food safety, food sovereignty, and economic freedom.

New Zealand has significant expertise and innovation in the sciences and in genetic engineering technology. However, the release of genetically engineered organisms from strict laboratory confinement any time in the foreseeable future would be misguided and potentially disastrous. The refusal of the Insurance industry to cover damage or risk from transgenic organisms is of particular significance, as is the abolition of the Bio-Ethics Council, which leaves our country, including government, without a visible moral compass, especially concerning the risks involved.

Released transgenes have the potential to invade and irreversibly damage the biological infrastructure of New Zealand's agricultural, horticultural, forestry and aquaculture sectors. Once released into the environment, transgenes spread and contaminate native and domestic gene-stocks alike. An example is the spread of ‘super’ weeds in the US and their presence in Europe. There are now many examples of weeds in the United States acquiring, from commercially grown transgenic crops, resistance to one or more herbicides, in particular glyphosate, the active ingredient in RoundUp Herbicide. See Superweeds, Organic New Zealand, January/February 2011 Vol 70 No 1 for more information.

See also www.weedscience.org/In.asp for a survey monitoring the evolution of herbicide-resistant weeds and assessing their impact worldwide; enabled by the collaboration of weed scientists.

See also Ryegrass, Organic New Zealand, July/August 2010 Vol 69 No 4; and Biopharming animals in NZ, Organic New Zealand, May/June 2010 Vol 69 No 3.

We refer Council to ‘Evaluation of horizontal gene transfer monitoring experiments conducted in New Zealand between 2004 and 2009’, Heinemann J, Kurenbach B and Bleyendaal N, 2011, Journal of Organic Systems; Vol 6; 1; 2011

www.organic-systems.org/journal/Vol_6(1)/index.html.

Nanotechnology

In our letter of 1 February 2011, we raised concerns about nanotechnology, which uses the building blocks of everything living and non-living by manipulating the properties of substances on a scale of 100 nanometres (nm) or smaller. One nanometre is one billionth of a metre.

When manipulated on this scale, the properties of a material can change, presenting both advantages and difficulties. For example, some nanoparticles can pass through epithelial surfaces (skin, gastrointestinal, conjunctiva) and the endothelial barriers lining blood vessels, or can be inhaled and can pass through the blood-brain barrier. Thus they could perhaps be used for targeted drug delivery in medical applications, but their widespread distribution in communities is likely to give rise to endemic low-level poisoning similar to what we now suffer from the use of herbicides and pesticides in food industries.

In New Zealand, regulations require companies to notify the Environmental Protection Agency (EPA; formerly handled by the Environmental Risk Management Authority) if they intend to import or manufacture cosmetics containing nanoparticles. Currently, regulations do not require manufacturers to state on the product that it contains nanomaterials. For consumer protection and choice, full labelling should be mandatory for all products containing nanomaterials.

More effective regulation is essential. A Review of the Adequacy of New Zealand’s Regulatory Systems to Manage the Possible Impacts of Manufactured Nanomaterials (Gavaghan C and Moore J, January 2011) expands on the gaps in the regularly process. See www.msi.govt.nz/assets/Nanotechnology-review.pdf.

As at December 2011, Food Safety ANZ claims it “has not received any applications to approve new or novel nanoscale particles for food use”, this despite the technology being used by the food industry. www.foodstandards.gov.au/consumerinformation/nanotechnologyandfoo4542.cfm.

PSGR maintains that safety assessments should also be mandatory for all manufacturing processes involving nanomaterials and require consent from Council for such use in the area where the business is operating. Concerns exist for employee safety, air contamination, consumer usage, trade waste disposal, and the effect on the environment. See our letter of 1 February 2011.

Nanotechnology may have potential benefits, but there is a distinct lack of understanding about the health and environmental impacts of nanoparticles and the significant risks they pose. For example, suggesting that foods naturally contain nanoparticles, and are thus acceptable, does not equate with manufactured nanoparticles in foods or food wrappings being acceptable or safe, or those in cleaning products, glass or shower shields as outlined in our letter of 1 February 2011, or any other nanomaterial product. A precautionary approach is essential for public and environmental safety.

The following articles provide more information: Nanotechnology: safe or not? Organic New Zealand September/October 2010 Vol 69 No 5 and Nano waste, How do we deal with it? Organic New Zealand November/December 2010 Vol 69 No 6. Also the PSGR 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 and TCC’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.

We again refer Council to www.ci.berkley.ca.us/ (enter nano waste in ‘search’) and suggest it take a further step by opening communications with the City of Berkeley in California, the first body worldwide to address nano waste.

Depleted uranium

Regrettably, the presentation of MP Phil Twyford’s Private Member’s Bill - Depleted Uranium (Prohibition) Bill - has been delayed; see www.legislation.govt.nz/bill/member/2010/0205/latest/DLM3224904.html.

We refer you to our comments in our letter of 1 February 2011 and to our Statement on Depleted Uranium March 2012; see http://psgr.org.nz/images/stories/psgr-statementondepleteduraniummarch2012.pdf.

We should appreciate Council sending us a copy of their statuary mandate for the preservation of the environment; email to This email address is being protected from spambots. You need JavaScript enabled to view it. or hard copy to PO Box 8188, TAURANGA 3145. Thank you.

Signed by the Trustees

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