2019 Submission Hazardous substances assessments: Improving decision-making.

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Submission to the Environmental Risk and Innovation - Ministry for the Environment:

Hazardous substances assessments: Improving decision-making.

September 29, 2019

Link to the Ministry for the Environment and to the Discussion Document (Publication reference number: ME 1426)

1. Physicians and Scientists for Global Responsibility welcomes the proposal by Ministry for the Environment (MfE) of the ‘trusted regulator’ approach. New Zealand’s low rate of reassessment to ban toxic chemicals does not fit the perception that New Zealand is a safe and nourishing food supplier, and it risks the slow decay of international goodwill that New Zealand is a trusted food source.

2. Regulatory science is extraordinarily political, but this does not mean that it should use lack of resourcing to delay protections of public and environmental health. As such, many issues that have been represented by the public over previous decades are ignored by regulators. Consultation is framed in such a way that the terms of reference retain contested issues outside of consultation. All too frequently the wider scrutiny of the published literature is simply not undertaken, and the few reassessments that happen are pushed through, with little participation from the wider public and independent scientific or public health community, - and with heavy reliance on industry data to facilitate the process. Reassessment rarely happens in New Zealand. When it does happen, it reflects industry influence, rather than best practice regulation.

3. We have separated the submission into Part 1 which illustrates the gaps and entrenched problems in assessment and Part 2 which attempts to directly respond to the 50 questions contained within the MfE document(MfE, 2019).

4. Part 1.

5. Discussion documents and consultation to the public frequently leave scientifically important, but politically controversial issues outside the term of reference. Without resourcing, monitoring and a regulatory environment that is evidence based, unbiased and utilises best practice, the New Zealand government and staff cannot protect human or environmental health.

6. The HSNO Act (Pesticides) requires updating, as Catherine Iorns has suggested (Iorns, 2018, p. 11). Particular criticisms of the current hazardous substances/risk assessment system include

the extrapolation from animal testing to humans is inadequate and relies on models and assumptions that may not be accurate, and some of which have been questioned
the “dose-response relationship” cannot be assumed at low-dose levels; for some chemicals it is neither linear nor algorithmic but more of a “U” shape, with serious effects at extremely low levels of exposure;
testing will typically only focus on the pesticide’s primary mechanism and not on other side effects; for example, neurotoxicity testing of organophosphates usually only requires consideration of one mechanism, that of cholinesterase inhibition, and fails to test for developmental neurotoxicity, despite the considerable and expanding literature illustrating the non-cholinergic neurotoxic effects;
testing for developmental immunotoxicity is generally not carried out, nor are allergic, inflammatory or autoimmune effects looked for;
endocrine disruption is not tested for; this takes a long time to show up, can occur at very low-level exposures, and can be passed through to future generations; for example the damaging impact of pesticides on mammary gland development can have an impact on the development of breast cancer later in life;
children and the foetus are especially vulnerable to single, low doses; the high dose protocols fail to consider exposures that are environmentally relevant especially to the unborn and newborn, and fail to target various organ systems at critical stages of development from foetal life through to adulthood;
risks are estimated for a single chemical at a time, so chemicals are tested in isolation when people and the environment are in reality exposed to mixtures of various chemicals, including adjuvant chemicals that are added to the pesticide active ingredient; testing thus generally fails to consider the impact of ubiquitous exposure on society as a whole;
existing body burdens of chemicals and cumulative effects are ignored in determining safe exposures;
some individuals are particularly sensitive to different chemicals such that adverse effects show up at lower doses than are considered acceptable for the average person; plus different individuals react differently to interactions of combinations of chemicals;

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