NZEPA - revoke all Chlorpyrifos uses in New Zealand entirely.
PSGR urge NZEPA to not backslide and match Australia's partial revocation.
PSGR’s submission included 4 appendices:
Appendices to PSGR’s original submission:
[A] PSGR December 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.
[B] PSGR: Three page information document Chlorpyrifos and risk. (PDF of this Substack that you are currently reading).
[C] Re: PSGR brassica discussion (in submission). Effects of Ozonated Water on Horticultural Products and Future Applications.
[D] Re: PSGR brassica discussion (in submission). Growlink testimony and customer information.
One of our appendices [B] was this short discussion on why chlorpyrifos should be banned PDF version of this article.:
PSGR welcome the opportunity to send in a response to NZEPA’s proposal to ban chlorpyrifos APP204694. [1][2][3][4] Thirty years of epidemiological and laboratory research has produced a weight-of-evidence that demonstrates that chlorpyrifos is a developmental neurotoxicant.
NZEPA has an obligation to consider risk to human and environmental health (domestic), and risk to trade (export).
The U.S. Environmental Protection Agency (USEPA) [5] [6] and the European Food Safety Authority (EFSA) determined that the insecticide CPY and CPY-M inhibit the enzyme acetylcholinesterase (AChE). EFSA revoked approvals for the insecticide chlorpyrifos [7] and common cereal grain storage fumigant, chlorpyrifos-methyl. [8] The maximum residue level (MRL) for CPY and CPY-M in Europe is 0.01 mg/kg, the lowest level that can be measured by analytical laboratories. [9]
EFSA revoked authorisations based on uncertainty relating to CYP and CYP-M’s genotoxic potential and the evidence of brain alterations, noting that the recorded toxicological effects meet the criteria for classification as toxic for reproduction category 1B (regarding developmental toxicity). For example (2019a, page 8):
It is well known that morphometry of brain regions is a valuable data for regulatory authorities (Tsuji and Crofton, 2012): the decrease in cerebellum height corrected by brain weight was considered an adverse effect indicating a damage of the architecture of the developing brain (in 2014, the PPR Panel considered the relevance of morphometric analyses as endpoint for hazard characterisation 4 ). The structural changes in the developing rat brain found in regulatory studies are consistent with human data. In particular, children with high prenatal exposure to chlorpyrifos showed frontal and parietal cortical thinning (Rauh et al., 2012).
AChE, binds to the neurotransmitter acetylcholine (ACh), mediating levels in the body and brain to prevent bioaccumulation of acetylcholine, a neurotransmitter that is involved in memory, learning, attention and muscle movement. The role as a neurotransmitter in the autonomic nervous system is particularly important.
Prenatal, early postnatal, and adolescent brain maturation is physiologically regulated by acetylcholine (ACh).
The conclusion of regulatory agencies that AChE activity was inhibited in erythrocytes (red blood cells) which are throughout the body, was an important step in the process of recognising the risk from CPY and CPY-M.
It was not just the brain that was at risk.
FOOD CONTAMINATION AND TRADE RISK
High residue levels in meat and animal and dairy fat is derived from feed that has been treated with CPY and CPY-M. 10 In New Zealand this may be either domestically grown feed, or imported feed, predominantly from Australia. As an exporter of meat and dairy products into Europe (with MRLs at 0.01 mg/kg), and other countries that have restricted CPY and CPY-M, New Zealand must recognise that there is a trade-related risk, if CPY and CPY-M contaminated feed is fed to livestock.
A second trade-related risk comes from food exporters who use food ingredients from Australia, who may be unaware that Australian tolerances for CPY and CPY-M are orders of magnitude higher than European limits.
In September 2024, the Australian Pesticides and Veterinary Medicines Authority (APVMA) removed 79 of 91 agricultural and urban pest control uses of chlorpyrifos, citing trade-related concerns. [11] Australia has retained approval for Cole (brassica) crops (broccoli, brussels sprouts, cabbage, cauliflower), Clover seed crops, Forage crops, Lucerne, Lucerne seed crops, Medics, Agricultural, commercial and industrial areas (not publicly accessible), Container plants in soil or other growing media (commercial), Hides/skins, Potted ornamentals (commercial), Treatment of termite nest or colony (in wall cavities), Turf (commercial). [12]
Australian maximum residue levels for brassica crops are .05 mg/kg. Australia will permit CPY to be sprayed to a wide range of animal forage crops. Therefore, milk fat levels of CPY can be as high as 0.2 mg/kg and CPY-M 0.5 mg/kg, and meat fat CPY and CPY-M levels can be as high as 0.5 mg/kg. Cereal grain levels for CPY remain at 0.1 mg/kg. The highest levels are from grain storage fumigant CPY-M on cereal grains 10 mg/kg, lupins 10 mg/kg, wheat bran 20 mg/kg and wheat germ 30 mg/kg. [13]
Australia has kept its high MRLs for brassica crops. Vegetable growers in New Zealand have successfully grown brassica crops for the domestic market for a decade. One treatment, ozone, acts as a fumigant and suppresses insect populations at the first, second and third stages of the insects’ lifecycle. Due to negligible toxicity due to rapid dispersal in air, there are no with-holding periods, and windy days are not a problem.
As New Zealand’s north island is a large consumer of Australian-grown products, people will be exposed to these high residue levels. However, for value-added food-based industries, the high MRL levels, if the product is used as an ingredient in potential export product, will be a trade risk.
HUMAN HEALTH RISK
It is perplexing that worker re-entry risk for pre-conception and pregnant women has not been reviewed when the primary risk identified globally is to pregnant women, the foetus and young children. NZEPA’s dismissive and simplistic discussion on developmental neurotoxic risk suggests that officials may not have the skill-set for this work, but also results in misleading information being communicated to the public.
PSGR’s Report, which is supplementary to this comments paper shows that the NZEPA has stepped away from formal risk assessment, and cannot claim that assessments in 2012-2013 and 2024 reflect a level of rigor required for risk assessment.
Meriel Watts: ‘Children (from the prenatal period through adolescence) often react differently to chemicals than do adults because, compared to adults, they have different exposures, different vulnerabilities determined by critical windows of development, and a longer life ahead of them. “To protect children’s environmental health (especially for the foetus and the small child), it is important to understand when and how they can be particularly vulnerable to chemical exposures. Understanding the rapidly changing nature of the child is essential to understanding vulnerability to chemicals” (IFCS 2003).’ [14]
The NZEPA have not considered that New Zealand children have higher exposures of the common metabolite of chlorpyrifos, chlorpyrifos-methyl and triclopyr than children in the U.S., Spain, or Thailand. [15] The NZEPA could have investigated the findings from this 2022 New Zealand study, but have not done so.
There is no known level of exposure that is safe for pregnant women and the developing foetus.
‘One US study found that as little as 4.6 parts per trillion of chlorpyrifos in umbilical cord blood during gestation was associated with a drop of 1.4 percent in a child’s IQ, and 2.8 percent of its working memory.’ [16] [17]
Developmental delays are a problem in New Zealand infants and children. One-in-four New Zealand children were recently classified as having suboptimal developmental health [18] and special education needs has substantially grown over time. [19]
Despite having large agrarian communities across New Zealand, and females who play golf and could be pregnant (turf) the key risk exposures in pregnancy or in early life has been completely ignored in modelling scenarios for acute or re-entry risk and the problem of persistence and repeated exposures in workplaces (including agricultural settings). One dermal absorption study on time-pregnant Fischer 344 female rats is not good enough. The APVMA also failed to conduct any analysis of risk to pregnant women.
As Dr Meriel Watts discussed in the book
‘One study, which quantified exposure estimates for a population of young farmworker children in the USA, found that 95% of 115,000 different exposure scenarios and dose estimates posed a risk to children’s health from chlorpyrifos exposure (Beamer et al 2012).’
Watts drew attention to ambient exposures:
‘not just those rural children living on farms or near fields that are affected: ambient community (i.e. away from the fields) air monitoring data from agricultural regions of California showed that short-term chlorpyrifos exposure estimates exceeded the ‘acute reference dose’ (another way of saying an ‘acceptable dose’) for 50% of children; and non-cancer risks were higher for children than adults (Lee et al 2002).’
NZEPA ignored the problem of the persistence of chlorpyrifos and its metabolites in work environments to pre- conception and pregnant women. Slow degradation and repeated exposures to workers re-entering premises on a daily basis after spraying, and families living near sprayed fields was downplayed.
‘the half-life of chlorpyrifos in soil ranges from 20 to 120 days, with the formation of 3,5,6-trichloro-2-pyridinol (3,5,6-TCP) as the main degradation product. Other data indicate that the half-life can range from 2 weeks to more than 1 year. This high interchangeability of the half-life is related to the soil properties, which include the soil type, pH, moisture, temperature, organic matter and organic carbon content, and the microbial metabolism of CPF. The degradation of CPF is increased by higher soil temperatures with lower organic matter contents and lower acidity. Another important factor is the characteristics of the chlorpyrifos-based plant protection product (e.g., its composition, surfactant content, and other auxiliary compounds) and its method of application’ [20]
Because of the failure to address risk in pregnancy, and risk to the foetus, the previously set toxicological reference values of chlorpyrifos (EFSA, 2014): ADI 0.001 mg/kg bw per day, AOEL 0.001 mg/kg bw per day cannot apply.
PSGR finds the scientific reasoning by the NZEPA and APVMA to be poorly constructed and unfit for purpose.
PSGR recognise that as a small regulator, it is practical that the NZEPA follows regulatory decision-making on risk and hazard in other jurisdictions with more resources. NZEPA’s scientific evidence supplied in support of their APP204694 proposal demonstrates that the NZEPA are unwilling to:
Scientifically examine the basis of decisions from the agencies that they most claim to defer to; and
Reflect this reasoning in their communications to the public.
Highlight the role of epidemiological studies and the role of publicly available literature in supporting the decision-making of these jurisdictions.
Incorporate risk from dietary burdens into their assessment.
Articulate the issue of uncertainty and a precautionary approach where evidence is plausible.
Take into account the absence of data to derive a safe exposure level for the populations most at risk – preconception and pregnant women and infants and young children.
RECOMMENDATION
PSGR recommends that to ensure the protection of pregnant women, infants and children from chlorpyrifos exposures, and the risk from bioaccumulation of breakdown metabolites, that New Zealand follows the European precedents and adopts a 0.01 mg/kg maximum permitted level.
Please read PSGR’s submission to the NZEPA chlorpyrifos consultation for PSGR’s response to the NZEPA (based on its consultation questions) for more context, why immediate use where pregnant women may be exposed should be suspended, as well as information on why we recommend withdrawing all use on pasture and arable crops - and how farmers might protect their farms from grass grub and porina infestations.
PSGR Chlorpyrifos Report: The Erosion of Risk Assessment practice at the New Zealand Environmental Protection Authority, and the Australian Pesticides and Veterinary Medicines Authority. (December 2024)
REFERENCES
[1] NZEPA (2024) Staff assessment report – the application to reassess chlorpyrifos. October 2024. https://www.epa.govt.nz/assets/FileAPI/hsno-ar/APP204694/APP204694-Chlorpyrifos-staff-assessment-report.pdf
[2] NZEPA (2024) Science memo: APP204694 chlorpyrifos. October 2024. https://www.epa.govt.nz/assets/FileAPI/hsnoar/APP204694/APP204694_Science_memo_-chlorpyrifos.pdf
[3] NZEPA 2012. Consultation Report. November 2012. https://www.epa.govt.nz/assets/FileAPI/hsnoar/APP201045/c306354078/APP201045-Consultation-Report.pdf
[4] NZEPA (2012) Evaluation and Review Report. https://www.epa.govt.nz/assets/FileAPI/hsno-ar/APP201045/13c074049d/APP201045-APP201045-Evaluation-and-Review-report.pdf
[5] USEPA (2020) https://www.regulations.gov/document/EPA-HQ-OPP-2008-0850-0944
[6] USEPA (2015) https://www.regulations.gov/document/EPA-HQ-OPP-2010-0119-0020
[7] EFSA (European Food Safety Authority), 2019a. Statement on the available outcomes of the human health assessment in the context of the pesticides peer review of the active substance chlorpyrifos. EFSA Journal July 2019, 17(8):5809, 23 pp. https://doi.org/10.2903/j.efsa.2019.5809I
[8] EFSA (2019b) European Food Safety Authority (EFSA), Updated statement on the available outcomes of the human health assessment in the context of the pesticides peer review of the active substance chlorpyrifos-methyl. EFSA Journal November 2019, 17(11):5908, 21 pp. https://doi.org/10.2903/j.efsa.2019.5908
[9] European Commission Pesticides Residue Database. https://ec.europa.eu/food/plant/pesticides/eu-pesticides-database/start/screen/mrls
[10] EFSA (European Food Safety Authority) (2017), Brancato A, Brocca D, De Lentdecker C, Erdos Z, et al., 2017. Reasoned opinion on the review of the existing maximum residue levels for chlorpyrifos according to Article 12 of Regulation (EC) No 396/2005. EFSA Journal 2017;15(3):4733, 121 pp. doi:10.2903/j.efsa.2017.4733
[11] APVMA (2024) Final Review Technical Report September 2024. https://www.apvma.gov.au/sites/default/files/2024-10/Chlorpyrifos%20Final%20Review%20Technical%20Report.pdf
[12] APVMA (2024). Chlorpyrifos uses – summary of assessment outcomes in the final regulatory decision October 2024. https://www.apvma.gov.au/chemicals-and-products/chemical-review/listing/chlorpyrifos/chlorpyrifos-summary-assessment-outcomes-final-regulatory-decision
[13] Agricultural and Veterinary Chemicals (MRL Standard for Residues of Chemical Products) Instrument 2023 made under section 7A of the Agricultural and Veterinary Chemicals (Administration) Act 1992. Compilation No. 6 Compilation date: 9 November 2024 Includes amendments: F2024L01413
[14] Watts, M (2013). Poisoning our Future: Children and Pesticides. Pesticide Action Network Asia & the Pacific. https://www.panna.org/wp-content/uploads/2017/03/2013-PAN-AP-POISONING-OUR-FUTURE-Children-and-Pesticides-Book-v8-WEB-lo-res.pdf
[15] Li Y, Wang X, Feary McKenzie J, 't Mannetje A, Cheng S, He C, Leathem J, Pearce N, Sunyer J, Eskenazi B, Yeh R, Aylward LL, Donovan G, Mueller JF, Douwes J. Pesticide exposure in New Zealand school-aged children: Urinary concentrations of biomarkers and assessment of determinants. Environ Int. 2022 May;163:107206. doi: 10.1016/j.envint.2022.107206. Epub 2022 Apr 5. PMID: 35395578. https://www.tandfonline.com/doi/full/10.1080/03036758.2022.2093434
[16] Panuwet P, Siriwong W, Prapamontol T, Ryan B, Fiedler N, Robson MG, Barr DB. 2012. Agricultural pesticide management in Thailand: status and population health risk. Environ Sci Pol 17:72-81. https://www.sciencedirect.com/science/article/abs/pii/S146290111100195X
[17] Watts, Meriel, with Williamson, Stephanie Replacing Chemicals with Biology: Phasing out highly hazardous pesticides with agroecology ISBN 978-983-9381-70-2. https://files.panap.net/resources/Phasing-Out-HHPs-with-Agroecology.pdf
[18] Tahirah Materoa Moton, Paula Toko King, Stuart R. Dalziel, Sally Merry, Stephen P. Robertson & Andrew S. Day. (2023) The current and future state of child health and wellbeing in Aotearoa New Zealand: Part 2. Journal of the Royal Society of New Zealand 53:5, pages 549-552. https://www.tandfonline.com/doi/full/10.1080/03036758.2022.2093434
[19] Bourke R, Butler P, O’Neill J (2021) Children with Additional Needs: Report to the ACCORD. FINAL REPORT, June 2021. Institute of Education, Massey University. https://assets.education.govt.nz/public/Documents/learning-support/Children-with-Additional-Needs-Final-Report.-R.-Bourke-P.-Butler-and-J.pdf
[20] Wołejko, E. et al. (2022) Chlorpyrifos Occurrence and Toxicological Risk Assessment: A Review. Int. J. Environ. Res. Public Health 2022, 19, 12209. https://doi.org/10.3390/ijerph191912209
