Pesticide/neonicotinoid submission

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Submission to: Hazardous Substances, Environmental Protection Agency
Submission Author: Mischa Davis, Policy Advisor
Wednesday, September 7, 2016

Hazardous Substances
Environmental Protection Authority
Private Bag 63002
Wellington 6140
Submission on application to import the insecticide Celsius


1.    The Soil & Health Association of New Zealand Inc. (Soil & Health) was incorporated under the Incorporated Societies Act 1908 on 4 December 1942. Soil & Health’s objectives broadly include soil health and the promotion of organic gardening and farming. It has approximately 3000 members, chiefly composed of home gardeners and consumers, organic farmers and growers, secondary producers, retailers and restaurateurs. Its age and membership make it the oldest and largest representative organic organisation in New Zealand.

2.    Soil & Health is opposed to the use of harmful pesticides in Aotearoa New Zealand. As an organisation we advocate for farmers and growers to adopt natural, organic, non-harmful methods of pest and disease management. We believe that researchers, farmers and growers should be encouraged to develop and implement nonchemical alternatives to pesticides that foster soil microbial life instead of destroying it.

3.    Soil & Health opposes the application to import Celsius into New Zealand due to it containing Thiamethoxam as the active ingredient, which is a toxic neonicotinoid. A number of independent scientific studies have raised serious concerns about the effect neonicotinoids such as Thiamethoxam have on honeybees. A number of countries have banned the use of neonicotinoids due to their harmful effect on bees, until further research is completed. We consider that New Zealand should follow suit.

Detailed submissions

4.    We are aware that Thiamethoxam is already approved for use in New Zealand by the Environmental Protection Authority (EPA) and is registered as an insecticide by the Ministry for Primary Industries (MPI). We understand that this neonicotinoid is already widely used in the New Zealand environment. It was introduced in 1997 in New Zealand, then approved for use in almost all European countries and also registered in the USA and Australia. We consider that the use of this neonicotinoid is already contributing to Colony Collapse Disorder in bees.
EU ban on Thiamethoxam

5.    In 2013 The European Commission voted in favour of a two-year ban of three neonicotinoids, due to their adverse effects on insect populations and a dramatic drop in bee population, and was backed by the European Food Safety Authority (EFSA). The three neonicotinoids were banned from use for two years on flowering crops such as corn, oilseed rape and sunflowers, upon which bees feed. Included in these three was Thiamethoxam. 15 out of a total 27 EU member states supported this restriction. It was stated by EFSA that they posed an “unacceptable” danger to bees. EFSA is currently undergoing a review of this ban however the results of the review could strengthen and tighten the current ban.

Adverse effects of Thiamethoxam
a)    Adverse effects on bees
We disagree with the proposition in the application that Celsius is unlikely to pose a risk to bees and other beneficials when used as intended. Since 2006 honeybees have been dying at a staggering rate in many parts of the world due to Colony Collapse Disorder. Research has shown that neonicotinoids, including Thiamethoxam, are highly toxic to a range of insects, including honeybees and other pollinators. Neonicitinoids can cause significant issues for the health of individual honeybees as well as the overall health of the honeybee colonies. Effects include disruptions in mobility, navigation, feeding behaviours, foraging activity, memory and learning and overall hive activity. Scientists are concerned that exposure to even low doses of neonicotinoids can confuse bees, making it difficult for them to source nutrition or safely return to their hives. One study has suggested that Thiamethoxam, at certain levels, can have negative effects on the bees’ pollination abilities, causing colonies to visit fewer flowers and return with less pollen, and resulting in apples with fewer seeds. This in turn can result in poor fruit quality and a risk of decreased agricultural output down the line. Bees and other insects are vital for global food production as they pollinate three-quarters of all crops. New Zealand’s bee population contribute about $5 billion to our economy annually. MPI has even stated: “Bees are crucial to New Zealand’s primary sector, pollinating around one third of our food sources”. New Zealand’s mānuka honey is internationally renowned and a unique high value export. It is some of the highest valued honey in the world.

b)    Adverse effects on waterways
We disagree with the proposition in the application that the use pattern and controls will mean that exposure to aquatic environments is highly unlikely. The application itself states that Thiamethoxam has a high degree of aquatic ecotoxicity and is harmful to aquatic organisms. We consider that exposure to aquatic environments is inevitable through rain and run-off, the application even states this:  “Celsius could be washed off into waterways following application, resulting in exposure of aquatic organisms.“ The application further states “under conditions of normal use, the product is not expected to end up in water bodies or water ways. It is to be applied at a water rate that ensures complete coverage but without runoff into water bodies” and that “Therefore, Celsius is not expected to pose significant risks to the aquatic.” We argue that ‘normal use’ is not a sufficient indicator of what use is, nor does the application describe what normal use is. A report by the organization Arinka funded by the European Union stated that Thiamethoxam is “very toxic to aquatic organisms/may cause long-term adverse effects in the aquatic Environment.  New Zealand’s waterways are already in a dire state with a staggering 62% of monitored waterways being unsafe for swimming. We consider that allowing the importation of Celsius into New Zealand will further put New Zealand’s waterways as risk.

c)    Adverse effects on humans
We disagree with the application in its statements that “the herbicide presents a low risk to humans and the environment when handled and used correctly.” Due to Thiamethoxam being used as a pesticide on crops we consider that there is a real possibility that residues may contaminate crops. There are various long-term effects associated with particular pesticides that are found in our food, including endocrine or hormonal disruption, cancer, immune system effects, nervous system damage, genetic damage, infertility and birth defects. There is also the risk of occupational exposure, which may occur though inhalation and dermal contact when Celsius is being applied in the field. Mild to moderate poisoning of Thiamethoxam can cause nausea, vomiting, diarrhea, abdominal pain, dizziness, headache, and mild sedation. Severe poisoning can cause seizures, coma, respiratory failure, and even death. Furthermore the application admits that there is a risk that spray drift could occur “resulting in off-target effects and bystander exposure”. We consider that merely having “an economic incentive to ensure the product is applied under circumstances that maximize the amount of active reaching the target area” is not going to mitigate the risk of spray drift.
Failure to meet requirements under HSNO Act

6.    Due to the adverse effects of Thiamethoxam listed above, we consider that if the EPA allows for the importation of Celsius into New Zealand it would be failing to recognise and provide for the life-supporting capacity of air, water, soil and ecosystems, as required to do under section 5(a) of the HSNO Act.

7.    Section 6(e) of the HSNO Act requires the EPA to take into account the economic and related benefits and costs of using a particular hazardous substance. New Zealand’s agriculture and horticulture industry is an important one. We have a large fruit production and export economy. In light of the importance of honeybees and other pollinators to New Zealand’s agriculture and horticulture we consider that importing Celsius into New Zealand puts these industries at risk. If bee populations continue to decline the cost of replacing bee pollinators by other methods in New Zealand would be impossible. The result therefore would be a drop in crop production, a huge rise in food prices, and probably loss of international markets.

8.    We consider allowing Celsius to be imported into New Zealand would adversely affect the sustainability of native and introduced flora and fauna, the intrinsic value of ecosystems, and the relationship of all New Zealanders, especially Maori over their culture and traditions, regarding valued fauna. We consider that the economic loss involved in the matters outlined above outweighs the economic gains of using the pesticide.
Alternatives to Celsius and other toxic pesticides

9.    Conventional agriculture relies on pesticides to protect crops from pests and diseases, including synthetic herbicides to control weeds, and synthetic fertilisers to promote crop growth. Over time this heavy use of synthetic chemicals reduces the soil biota and the productive capacity of the soil, and creates increased resistance by pests to the chemicals used, as well as the resurgence of secondary pests. These chemicals are also dispersed in the environment, polluting waterways and damaging ecosystems.

10.    Numerous studies on the adverse impacts of pesticides and chemical fertilisers have raised awareness about the use of synthetic chemicals in agriculture, how effective they actually are in treating pests and diseases, and the impact they are having on human health as well as the wider environment. People are turning to more natural forms of pest and disease control that are more effective, sustainable and healthier in the long term.

11.    Organic agriculture has a holistic approach to pest and disease management that avoids the need for pesticides by instead focusing on building healthy fertile soil with abundant microbial life, fostering natural predators and using natural remedies. Truly well-nourished plants do not attract pests or provide a suitable conditions for pests and diseases to develop. Farmers and producers try to create healthy soil so that plants and animals can be healthy, and build up good natural defenses against pests and diseases. The long-term health of the soil is taken into consideration, rather than trying to deal with the immediate problem with synthetic sprays.

12.    There are already many similar insecticides on the market in New Zealand. We consider that even those insecticides currently available can easily be replaced by non-chemical biological controls that do not have an adverse effect on the environment. We therefore consider that Celsius does not provide any extra advantage.

13.    Due to the many adverse effects associated with the use of Celsius as well as the lack of convincing evidence of both its need and safety we consider the EPA must take a precautionary approach as required under section 7 of the HSNO Act, and decline this application.

14.    We further request that all existing products using Thiamethoxam have their approval withdrawn for any importation, storage, sale, copating, or dispersal, until international scientific evidence exonerates this neonicotinoid from any linkage with honey bee deaths and Colony Collapse Disorder.

15.    Soil & Health wish to be in heard in support of our submission.

Yours sincerely

Mischa Davis
Policy Advisor

The Soil & Health Association
PO Box 340002
Auckland 0746
Phone: 06 8775534
Mobile: 0212667754