CHLORPYRIFOS REPORT: The Erosion of Risk Assessment practice at the New Zealand Environmental Protection Authority, and the Australian Pesticides and Veterinary Medicines Authority. (2024)

WHAT IS GOING ON?

Revocations of the insecticide chlorpyrifos and fumigant chlorpyrifos-methyl have followed regulatory assessments of the weight-of-evidence which strongly suggests these substances are development neurotoxins. Uncertainty extends to their potential genotoxicity.

There is strong evidence that the greatest dietary burdens arise from the permitted higher residue levels of chlorpyrifos-methyl on fumigated cereals, and the higher quantities of cereals that are consumed in the diet, particularly by low-income families.

On November 14, 2024, an New Zealand Environmental Protection Authority (NZEPA) press release announced a call for submissions relating to a proposed ban for chlorpyrifos. Submissions close at 11.59 pm on 12 February 2025. NZEPA’s assessment of risks and benefits are described in the staff assessment document ‘Staff assessment report – the application to reassess chlorpyrifos’. NZEPA claim that a ‘quantitative assessment of human health risks has also been undertaken’, this is found in the document ‘Science memo: APP204694 chlorpyrifos’.

One month before, in September 2024, the Australian Pesticides and Veterinary Medicines Authority (APVMA) removed most agricultural and urban pest control uses of chlorpyrifos (79 of 91 uses). The APVMA has pushed consultation of chlorpyrifos-methyl into the future.

PSGR HAVE CONCLUDED THAT:

Globally, regulatory agencies recognise that harm is not just to the brain but foetal development.
The NZEPA continue to exclude and downplay epidemiological evidence in regulatory reviews and risk-assessments. This is contrary to best practice.
Farmers may not be aware that chlorpyrifos and chlorpyrifos-methyl share the same toxic primary metabolite that can be detected by foreign jurisdictions that have banned both substances.
This metabolite persists, and daily dietary and workplace exposures can result in chronic lifetime exposures.
Families may not understand that children can be exposed through cereal grains for human and animal feed imported from Australia, and that New Zealand may follow Australia to permit chlorpyrifos on common children’s vegetables, including broccoli.
The NZEPA do not conduct methods-based risk assessment, and when they claim to undertake assessment it is limited to reviewing the findings of weaker regulatory jurisdictions.
New Zealand has fallen disastrously behind other countries in introducing a ban and tends to follow low-bar regulatory jurisdictions such as Australia which continues to permit chlorpyrifos use on brassicas and animal forage crops; and chlorpyrifos-methyl on cereal grains.
New Zealand faces a trade-related risk if chlorpyrifos and chlorpyrifos-methyl contaminated feed is fed to livestock and this livestock is imported into the European Union.

DOWNLOAD THE PDF: 2024 Report: The Erosion of Risk Assessment practice at the New Zealand Environmental Protection Authority, and the Australian Pesticides and Veterinary Medicines Authority. The case of chlorpyrifos and chlorpyrifos-methyl. December 2024.

PSGR RECOMMEND THAT:

An inquiry is held to assess New Zealand risk assessment practices are fit for purpose, including assessment of the role of epidemiological data, publicly available data and dietary burdens.
The New Zealand government urge Australia to revoke all tolerances on chlorpyrifos-methyl in order to stop the practice fumigation of cereal grains.
Applications on brassicas cease as other treatments, such as ozone (O3) are safer.

With bans of residential and public use, New Zealand urban exposures will derive from imported fumigated cereals, predominantly from Australia. Neither the NZEPA nor the APVMA have appropriately engaged with the global weight of evidence that strongly suggests that chlorpyrifos-containing substances and chlorpyrifos-methyl drive developmental neurotoxicity.

Some chlorpyrifos-methyl registrations have been voluntarily withdrawn in Australia, but the APVMA have not confirmed if all chlorpyrifos-methyl fumigation of cereal grains has stopped.

THIS REPORT HAS TWO AIMS:

Firstly, PSGR seek to draw attention to the declining quality of regulatory risk assessment and the continued exclusion by the NZEPA of new data and of epidemiological evidence as to risk, and that the New Zealand public are under-served by the continued erosion in risk assessment practice. The NZEPA claim that they do not have to address dietary burdens as a component of risk assessment, PSGR consider that this is incorrect and misleading.

Secondly, we aim to stimulate discussion on NZEPA’s failure to assess risk to pregnant women, the developing foetus, infant and child from exposures that may arise from local agricultural spraying and/or dietary exposures. Women who might work in or near, or live in vicinity to chlorpyrifos-sprayed sites will be exposed on a daily basis for days after, as the substance can persist for weeks.

Download