Previously known as Physicians and Scientists for Responsible Genetics PSRGNZ - Charitable Trust
As required under the new 2005 Charities Act, PSGR has reregistered as a charitable trust.

22 January 2018           

To all New Zealand Councils and Councillors                   cc District Health Boards and Public Health Services, Other interested recipients 

Formulating your Long Term Plans

PSGR is a not-for-profit, non-aligned charitable trust whose members are mainly science, medical and machinery-of-government professionals.  Since the Royal Commission on Genetic Modification made recommendations “to proceed with caution”, PSGR has maintained a watching brief, in particular on scientific developments in genetic engineering (also referred to as genetic modification), as well as other public interest issues involving health and environmental safety where we can offer expert opinion on lawful and authoritative public policy information.

Please consider this information and recommendations as a submission by PSGR to your planning development and consultation 2018.  PSGR will speak to this submission.

In forming responsible and effective governance

The responsibility to ratepayers and the wider community requires informed decision-making, including consideration of new information and peer-reviewed science that may challenge perceived wisdom, or current policy assumptions.  In many situations an intergenerational perspective is required.

In this submission regarding your Long Term Plans we ask Council to consider the following issues to be addressed:

  • Providing drinking water free of fluoridation;
  • Protection against contamination of land and waterways by genetically engineered organisms;
  • Urgent reduction of public, crop and animal exposure to glyphosate-based herbicides.

Appropriate policy and planning responses to these issues are also provided in PSGR’s recommendations at the end of each following section.

 

  1. Drinking water free of added fluoride and associated bio-accumulative, toxic contaminants

We refer you to our letter recently sent to MPs, attached here for your convenience.

Further to that letter, a paper has just been accepted for publication concerning the cost-benefits of water fluoridation.[i]  Unfortunately, the authors have made seriously flawed assumptions together with erroneous statements of fact.  As an example, they claimed that fluoridation has resulted in a nationwide 40% reduction in decay and thus by extension, huge cost savings.  This was an inappropriate extrapolation from an isolated cohort of deprived children mentioned in the 2009 Sapere Report that specifically stated that its findings should not be used to evaluate any fluoride benefits.  The authors appeared to have ignored another and much more detailed paper.[ii] 

In that more detailed paper, there are direct quotes from those involved in running fluoridation plants:

In 2010, amid a budget crisis, the City of Sacramento, CA, instructed all departments to review programmes and services.  Mr Marty Hanneman, then Director of the Department of Utilities, wrote in a memo to the City Council:

The City of Sacramento has been fluoridating its water supplies just over 10 years.  Within that time, the actual cost of operating and maintaining the fluoridation systems has proven to be considerably more than the initial estimate. . . . The fluoridation infrastructure at the E A Fairbairn Water Treatment Plant is overdue for replacement and will be very expensive to replace . . . Fluoridating water is a very costly and labour intensive process and requires constant monitoring of fluoride concentrations to ensure proper dosages. . . . The chemical is very corrosive, so all equipment that is used in the fluoridation process has a very short life expectancy and needs to be replaced frequently. . . . but also causes frequent and complex systems failures.

This was echoed by Mr René Fonseca of Carroll Boone Water District in Eureka Springs, AR, which was required by a 2011 State mandate to begin Community Water Fluoridation (CWF)[iii]:

All of our chemical feed systems require regular maintenance which is routine, but fluoride feed equipment often requires replacement and more frequent attention. . . . I have toured plants and seen in trade publications deteriorating pipes, steel doors and casing, electrical components, etc.  There are millions of dollars spent yearly on infrastructure damage caused by fluoride in our industry.

The realities expressed in these two quotes are not the exceptions. 

A water plant manager in Alberta, Canada, complained that the fumes from the fluoride acid etched the glass, paint, and computer screens of the water treatment plant.

Seven years after CWF began in 2001, Riverton, Utah, spent nearly US$1.2 million for two new buildings “to get fluoride out of electrical and pump area.”

The international evidence is that the installation and long-term maintenance of water fluoridation is very expensive on the rate-paying public.  The rationale is highly questionable. 

Recommendation

PSGR recommends that Council does not fluoridate drinking water on the grounds that it is not lawful to put bio-accumulative toxins into people and the environment.

 

  1. Genetic engineering

We refer Council to our letter recently sent to New Zealand Members of Parliament and copied to Councils.  This is attached for your convenience.

We refer particularly to Councils in Northland, Auckland, Bay of Plenty and Hawkes Bay that have worked to protect their ratepayers from the risks of releasing genetically engineered / modified organisms into the environment; and the risks to health, horticulture, agriculture and exports.  See http://www.wdc.govt.nz/ PlansPoliciesandBylaws /Plans/Genetic-Engineering/Documents/GE-Poll/GE-Poll-Results-WDC.pdf

Under the new Resource Legislation Amendment Act 2017 Councils retain the right to safeguard their region.  Councils have responsibilities and powers under the Act that can add another important layer of protection.

Although there is a view among some councils that public policy on matters relating to genetic engineering can be safely left to New Zealand’s Environment Protection Authority (EPA) there is adequate evidence that shows that EPA’s oversight of these matters is biased to industry interests (through being partial and selective) and therefore does not give due weight to public and environmental safety issues – and therefore the public interest.

Therefore, EPA’s claimed policy on genetic engineering matters is arguably inconsistent with the purposes and intent of the Hazardous Substances and New Organisms Act 1996.  Therefore, such

Deficiency suggests that the EPA’s policy does not have any statutory authority in law – and cannot therefore be relied upon by councils in giving effect to their statutory obligations. 

Recommendations

On this issue, PSGR recommends that Council gives weight to the findings of the Union of Concerned Scientists (UCS) on Food and Agriculture.  On genetic engineering in agriculture the UCS found that the risks have been exaggerated, but so have its benefits and that we have better, more cost-effective options.  You can find their reports on http://www.ucsusa.org

PSGR also recommends that Council draws on the experience of Northland, Auckland, Bay of Plenty and Hawkes Bay Councils – i.e. concludes that the risks involved require responsible legislation to reflect the precautionary principle on any proposed release of a genetically engineered organism into the environment in Council’s area of jurisdiction.  Such a decision on the facts presently available will indicate to the public that Council exercises its statutory powers reasonably and in accordance with the factual and authoritative information presently available.

 

  1. Use of glyphosate-based herbicides (GBH) – unconscionable on the facts

Despite New Zealand’s Environmental Protection Authority rejecting a statement by the World Health Organisation’s International Agency for Research on Cancer (IARC), that glyphosate is “possibly carcinogenic to humans” (category 2B), there is substantial scientific evidence supporting an IARC statement that glyphosate-based herbicides are a risk to the environment and to human health. 

Glyphosate is the active ingredient in the glyphosate-based herbicide Roundup and many other brands of GBH herbicides.  Once used, it is pervasive in the environment.  Residues were recently found in samples of 45 percent of Europe’s topsoils[iv] and in the urine of three quarters of German participants.[v]  A previous study by the Heinrich Böll Foundation, in analysing glyphosate residue in urine, concluded that 75% of the target group displayed levels that were five times higher than the legal limit for drinking water, and one third of the population showed levels between ten and 42 times higher than what is normally permissible.  Glyphosate has been detected in breast milk and in honey samples taken from sites around the world.

Although manufacturers and other advocates say there is no certainty of the biological significance in the presence of the herbicide in people, this is belied by the latest analysis of cancer risks, glyphosate’s action as a registered antibiotic, and findings of its use in agriculture impacting emerging problems with bacteria resistant to antibiotics.  See:

http://www.canterbury.ac.nz/news/2017/new-research-finds-common-herbicides-cause-antibiotic-resistant.html.

Glyphosate can enter the body through food or drinking water.  It can be inhaled through breathing in spray drift.  Foraging animals and pets are equally exposed.  Glyphosate can disrupt human cellular structure and function, and contribute to uncontrolled cell proliferation (a cancer-like characteristic).  The changes brought about in human skin cells by GBH are consistent with the changes that are seen in hepatocellular carcinoma, lung cancer, colorectal cancer, and melanoma.

Very low concentrations of glyphosate have been found to stimulate unhealthy cell growth, while higher concentrations suppressed cell growth.  This indicates that the herbicide is a powerful disrupter of the endocrine system.  Such disruptions can therefore potentially disrupt all normal human-body-life-processes.  The greatest dangers may therefore be found in extremely low concentrations that are measured in parts per trillion, rather than in parts per million.

In one study, glyphosate residue was recorded in 99.6% of 2009 monitored participants.[vi]  Significant values were found in children and adolescents.  This study was the largest of its kind ever carried out.

Links to additional information on glyphosate

Recommendations

PSGR recommends Council refrains from using glyphosate as an herbicide in all places accessible to animals and humans including waterways and where spray drift could pose a risk to people and could damage food crops.  Less invasive methods are available. 

We can supply further authoritative information on fluoride, genetic engineering and glyphosate-based herbicides if that would be helpful to Council. 

Please consider this information and recommendations as a submission by PSGR to your planning development and consultation 2018.  

The Trustees of Physicians and Scientists for Global Responsibility New Zealand Charitable Trust

References

[i] David Moore1, Matthew Poynton1, Jonathan M. Broadbent and W. Murray Thomson. The costs and benefits of water fluoridation in NZ BMC Oral Health (2017) 17:134 DOI 10.1186/s12903-017-0433-y

[ii] Lee Ko, Kathleen M. Thiessen. A critique of recent economic evaluations of community water fluoridation. International Journal of Occupational and Environmental Health 2015 Vol. 21 No.2

[iii] Fonseca, 2012, private communication

[iv] http://www.pan-europe.info/sites/pan-europe.info/files/Glyphosate-published.pdf   

[v] https://www.euractiv.com/section/agriculture-food/news/overwhelming-majority-of-germans-contaminated-by-glyphosate/

[vi] https://www.euractiv.com/section/agriculture-food/news/overwhelming-majority-of-germans-contaminated-by-glyphosate/