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.

15 February 2014

CEOs, Mayors and Councillors of all Regional, District and City Councils in New Zealand,

cc Local and Community Boards, and CEOs and Board Members of all District Health Boards

Submission to Councils Future Community and Regional Plans

The Trustees of PSGR thank Council for their response to previous correspondence.  We ask that you accept and consider the following concerns as a submission when establishing your planning and budgeting documents and in so doing supporting a sustainable future for your district and a healthy community, and in doing this draw support from members of District Health Boards and Community and Local Boards.

Physicians and Scientists for Global Responsibility is a Charitable Trust established to provide independent scientific assessment and advice on matters relating to genetic engineering and other scientific and medical matters.  We offer the following: 

Genetic engineering

Field trials of transgenic canola took place in Tasmania in the late 1990s and 2000.  Observing the effects, the Tasmanian Government decided to pursue agriculture that is free of genetically engineered organisms.  Management issues of the former trial sites included seed persistence.  Consequently, an annual audit of sites has taken place.  The most recent was in May 2013, with all 53 sites inspected.  Four sites had canola volunteers.  In 2008, volunteers were found at twelve of the 53 sites,[1] twelve different sites to the 2013 audit.  During audits, nearby roadsides and other areas are inspected to ensure containment is being achieved.  This policy has been maintained and strengthened with a recent decision for an indefinite moratorium on release of GMOs to protect their brand and export economy.[2]

Over half the 2013 sites had not involved recent soil disturbance and it was acknowledged that these will have dormant canola seed in the soil that will not germinate until soil disturbance takes place.  The Office of the Gene Technology Regulator (OGTR) advises canola seeds can be viable for up to 16 years.[3]   

Australian farmers growing conventional canola have regularly secured a higher price for their crops.  Exporters can check a list of countries that ban transgenic crops and require food labelling for any transgenic element on


The foregoing is just one indication of why New Zealand should preserve itself as a GE-free nation.

Following community requests, the Bay of Plenty Regional Council included a precautionary statement on transgenic organisms in its Proposed Regional Policy Statement. 

An appeal by Scion (NZ Forest Research Institute) went to the Environment Court.  The Court decision released on 18 December 2013[4] allowed the BOP RC to retain reference to transgenic organisms in its Regional Policy Statement. 

The Court’s decision sets a precedent.  It clearly indicates that the Resource Management Act can be used to manage such activities in the Bay of Plenty region and it will also assist any future case in front of the Environment Court on this emerging issue. 

Communities and industries in the Bay can now work towards the inclusion of stricter rules in their District and City Plans to protect and keep their ‘GE-free’ environment status and marketing advantage.  The Regional Policy Statement includes a policy directive to apply a Precautionary Approach to activities that have scientific uncertainty and where there is a serious risk of irreversible adverse effects.  This can apply to the use of transgenic organisms in the BOP environment.

The Environment Court recognised the community concerns regarding the outdoor use of transgenic organisms.  It also indicated in its decision that the Council may propose more directive regulation in the future, including policies, objectives, and methods.  These regulations would come as a result of further investigation (via a Section 32 report) showing that transgenic organisms are elevated to a matter of regional significance.  The Court decision will also encourage New Zealand Councils to take steps to protect their communities in a similar manner.

Local government’s role is to work in service to the public interest of present and future generations.  Local government responsibility encompasses the environmental and social spheres in their regions.  The precautionary approach as discussed here speaks to this responsibility in regards to new technologies such as the proposal to release transgenic organisms.  

A legal opinion by Dr Roydon Somerville QC on Managing Risks Associated with Outdoor Use of Genetically Modified Organisms (January 2013) is available on Plans/Genetic-Engineering/Documents/Proposed-Plan-Change/Legal-Opinions-combined.pdf.   

Also attached is a press release from the Inter-council Working Party on GMO Risk Evaluation and Management Options[5] which addresses some of the issues that Local government needs to consider in regards to the proposed uncontained use of transgenic organisms

Section 1.7 Precautionary approach4

The ability to manage activities can be hindered by a lack of understanding about environmental processes and the effects of activities.  Therefore, an approach which is precautionary but responsive to increased knowledge is required.  It is expected that a precautionary approach would be applied to the management of natural and physical resources wherever there is uncertainty, including scientific, and a threat of serious or irreversible adverse effects on the resource and the built environment. It is important that any activity which exhibits these constraints is identified and managed appropriately.  Although those intending to undertake activities seek certainty about what will be required of them, when there is little information as to the likely effects of those activities, public authorities are obliged to consider such activities on a case-by-case basis. Such consideration could be provided for in regional and district plans, through mechanisms such as zoning or rules enabling an assessment of effects through a resource consent process, or through other regulation such as bylaws.  Any resource consent granted in such circumstances should be subject to whatever terms and conditions and/or reviews are considered necessary to avoid significant adverse effects on the environment and protect the health and safety of people and communities.4

PSGR strongly endorse a precautionary approach to genetically engineered / transgenic organisms at all levels of government and regulation. 


The French parliament has adopted a law to prohibit private or public use of pesticides in green areas, forests or public space, to apply from 1 January 2020.[6]  While this is a relatively small portion of agricultural chemical usage, it is a start to protect communities.  PSGR urges Council to take similar action and ban the use of glyphosate-based herbicides in public places:  roadsides, parks, reserves, community gardens, etc.

Recent studies highlight the effects on people of glyphosate, the active ingredient in RoundUp and many other herbicides.[7]  Additional ingredients in some formulations are adjuvants and/or surfactants; e.g. polyethoxylated tallow amine (POEA), particularly toxic to animals and humans.  A study released in January 2014[8] confirms glyphosate formulations have agents added that may be more toxic than glyphosate.

Glyphosate residues are found in the main foods in the Western diet.  Negative impact on the body is insidious and manifests slowly over time, damaging cellular systems.  It plays a part in most of diseases and conditions associated with the Western diet, including gastrointestinal disorders, obesity, diabetes, heart disease, depression, autism, infertility, cancer and Alzheimer’s disease.[9]

A study has shown glyphosate was present in human urine samples taken from participants in 18 European countries.  The test results averaged 43.9% with the chemical present.[10]

A review paper on glyphosate (2013)[11] prepared for the Scottish Parliament is a compilation from independent scientists, toxicologists, beekeepers, environmentalists, governments, industry, and regulators worldwide.  The findings detail glyphosate’s negative impact on human health and the environment.   

To see a power-point presentation on glyphosate click on, scroll down and click on “(Powerpoint Slides) (PDF Version)” to ‘Glyphosate:  The Elephant in the Room’.  

PSGR urges Council to refrain from using herbicides containing glyphosate or its salts for spraying in public areas and refer you to further information in our letter to Councils of 25 October 2013.


Fluorine does not occur in the elemental state in nature, but exists in the form of fluorides in a number of minerals, of which fluorspar, cryolite and fluorapatite.  Fluorine compounds are used in the production of aluminium and phosphate fertilizers and is a waste product from those industries.[12]  Typically, fluoride used to fluoridate water supplies is a contaminated chemical by-product of the phosphate fertilizer manufacturing process, fluorosilicic acid.  It is concentrated, highly toxic and contains hazardous impurities.  Uranium and radium are two known carcinogens found in fluorosilicic acid used for water fluoridation, and polonium-210 is one of two decay products of uranium.  Polonium decays into stable lead-206, raising significant health risks, especially for children.  Research has shown that drinking fluoridated water increases lead absorption.

We recommend Council read ‘Public Health Investigation of Epidemiological Data on Disease and Mortality in Ireland related to Water Fluoridation and Fluoride Exposure’ (2013).[13]  This Report was compiled for the Government of Ireland, the European Commission, and the World Health Organisation.  It found public health authorities have pursued a policy of medicating the population with fluoridation chemicals for half a century without undertaking any clinical trials, medical, toxicological, scientific or epidemiological studies to examine how exposure to such chemicals may be impacting on the general health of the population.  In the absence of any scientific data proponents continue a policy as both safe and effective for all sectors of society regardless of the age, nutritional requirements, medical status or the total dietary intake of fluoride of individuals.

A lifetime exposure to fluoride can lead to health risks,[14] especially to those with challenged immune systems, the young and the elderly.  There is no antidote for fluoride toxicity and fluoride does not adsorb to activated charcoal in filters.[15] 

In the interests of public health, PSGR urges all Councils to maintain fluoride-free drinking water supplies.

Off- and on-shore drilling for oil and gas

Both of the above have raised strong public comment.  Of particular concern in 2014 are the results of potential accidents with off-shore exploration drilling being carried out by Anadarko Petroleum Corporation and later Shell, and the effects on-shore drilling and fracking oil wells will have on the environment, especially contamination of ground water and drinking water, and contamination of agricultural land used to grow animals and food crops.  The bedrock of the New Zealand’s economy is primary production, manufacturing and tourism, which sectors rely strongly on our ‘Clean Green’ reputation.  Oil pollution could destroy that status.

The Deepwater Horizon oil spill in the Gulf of Mexico began on 20 April 2010.  After several failed efforts, the well was declared sealed on 19 September 2010 although some reports indicate the well site continues to leak.  A total discharge of 4.9 million barrels (210 million US gal; 780,000 m3) has been estimated.[16]  The adverse effects continue in the health of people in the region, their livelihoods, and the environment.

The Rena grounding in October 2011 off Tauranga impacted on the environment extensively and proved how ill-equipped New Zealand is to handle oil spillages.[17] 

Despite the ship carrying just 1700 tonnes of heavy oil and 200 tonnes of diesel fuel,[18] over a thousand tonnes of sand had to be removed from local beaches, aided by hundreds of volunteers combing the sand by hand for oil globules for months afterwards.  More than two years later, such globules of oil can still appear.  It could have been much worse.  The Rena was a cargo ship rather than an oil tanker or – potentially even more dangerous – a deep sea oil well.

Following scientific principles shows the potential effect of oil spillage from the 2014 deep sea drilling sites being tackled by Anadarko.  Oil companies drilling in New Zealand are required to have contingency plans in the event of a blowout[19] and Anadarko has drawn up a ‘worst case’ accident scenario.  It cites a daily oil flow higher than the 10,000 barrels a day estimated by Greenpeace in October 2013, a figure dismissed as ridiculous by New Zealand’s Petroleum Exploration and Production Association and Prime Minister John Key.[20]  ‘Blowouts’ are acknowledged to be more likely during exploration than during production and the risks rise with deepwater drilling.  Because of the reported current lack of transparency in approving drilling permits, questions arise about ensuring that absolute best practice is applied. 

In the event of a blowout, Maritime NZ would have charge.  The Murdoch Review of Maritime NZ’s handling of the Rena disaster is disturbing.  Will the funding boost of NZ$2 million from government over three years to improve equipment and coordination be sufficient?  Deepwater Horizon should provide salutary lessons to ensure a safety culture leaving nothing to chance.  The US congressional investigation into that accident described the oil-spill response plan signed off by BP and Anadarko as “tragically flawed” and “embarrassing”. 

We refer Council to our website for detailed information on fracking[21] and to ‘Evaluating the environmental impacts of fracking in New Zealand: An interim report’[22] from the Parliamentary Commissioner for the Environment.  A second report is due in the first half of 2014.  Further sites are ‘NZ Petroleum Basins’[23], and ‘Briefing - Out Of Our Depth:  Deep-sea oil exploration in New Zealand and East Coast Basin’.[24]

Government maintains test-drilling applications should not have to go through a full public hearing process.  This is not acceptable in the interests of New Zealand and its citizens.  Exploratory drilling for oil and gas must remain publicly notifiable, open to public submissions and hearings.  We urge Council to actively participate in your community on this issue.

Nanotechnology and waste disposal

We remind Council of our letter of 10 February 2013.  In it we detailed evidence from hydroponic plant studies showing manufactured nano-materials can be taken up and processed by plants (Priester et al, 2012)[25]  

More recent studies[26] found manufactured nano-materials can impact on microbes and microbial processes related to nutrient cycling, to plant growth and composition if they are transferred from soil to plants.  Highly sensitive spectral analysis techniques have now enabled scientists to trace nanoparticles taken up from the soil by crop plants and thus into the food chain.[27] 

Releasing manufactured nanoparticles to the environment is a serious potential risk to human and environmental health.  Plants expose huge interfaces to their air and soil environment.  Nanoparticles are adsorbed to these plant surfaces, taken up through nano- or micrometer-scale openings of plants and translocated in the plant body.  Persistent nanoparticles associated with plants can thus enter the human food chain.[28]

Dispersing wastewater biosolids which may contain manufactured nano-materials on paddocks growing food crops could lead to agriculturally associated human and environmental risks.  Biosolids that may contain manufactured nano-materials are routinely dispersed on New Zealand paddocks and into water systems and treated sewage that may contain such particles is discharged into the sea.[29]

PSGR urges Councils and District Health Boards to work closely on developing safety measures in regard to manufactured nano-materials.  Potential gains from nanotechnology need to be weighed against the fact that science is increasingly being privatised and patents on nano-products and nano-technologies are growing rapidly.  Vested interest can too easily override issues of safety, regulation, and public consultation and interest.

Electro-Magnetic Radiation

Today society relies on electronics to an enormous extent and it is hard to accept that these functions can disrupt bodily health.  The American Academy of Environmental Medicine (AAEM) has called for precaution and more research into EMF, RF and general frequency exposure because of adverse health effects:  “It is clear that the human body uses electricity from the chemical bond to the nerve impulse and obviously this orderly sequence can be disturbed by an individual-specific electromagnetic frequency environment.”[30] 

Of concern are wireless systems in schools, libraries and work places.  We point Council to ‘Public health implications of wireless technologies’ (Sage and Carpenter, 2009).[31]  Of further concern are Smart Meters installed by electricity supply companies.  As of 22 January 2014, the number installed had reached one million units.[32]  

PSGR recognizes that electric and electronic devices, and infrastructure and wireless communication are accepted parts of modern life, that the recent rise in use of these technologies has dramatically increased human exposure to electromagnetic radiation (EMR) and/or electromagnetic fields (EMF).  Some applications of wireless technology would now be difficult to replace but we point to the warning issued by the European Environment Agency:  “There are many examples of the failure to use the precautionary principle in the past, which have resulted in serious and often irreversible damage to health and environments.  Appropriate, precautionary and proportionate actions taken now to avoid plausible and potentially serious threats to health from EMF are likely to be seen as prudent and wise from future perspectives.”[33] 

While the science on the health impacts of such radiation is not yet conclusive, many people are concerned about how long-term exposure to excessive EMR may impact human health and nature.

PSGR asks that Councils and District Health Boards recognise that electromagnetic disturbances are on the increase and that understanding and controlling the electrical environment is essential for the protection of individuals and communities.  Using safer technology such as fibre optics and other non-harmful methods for data transmission will assist the process.

‘Refuse, reduce, reuse, repair, recycle and rot’

In 2013, Dunedin City Council adopted a Waste Management and Minimisation Plan.  Its vision statement is:  Dunedin, a sustainable city in which 'waste' is transformed into a beneficial material or is returned benignly to nature.  See for details.

In Nelson, 92% of citizens recycle.  See

PSGR urges all Councils to follow these examples and also work to achieve a target of zero waste to landfill.

Council’s Future Plans

PSGR urges all Councils to apply strong precautionary policies on genetically engineered organisms and on nanoparticles for Unitary, Local and Regional plans to meet your duty of care to your community and to protect district environments.  We call on Councils and District Health Boards to be cognisant of the risks of genetically engineered organisms, nanoparticles, glyphosate-based herbicides, fluoride and EMR/EMF in terms of human health. 

Councils and DHBs represent their community.  Duty of care should always take account of public opinion, health and safety.

Response to this submission to local community and regional plans

As stated earlier, please consider this correspondence as a formal submission to your plans.  

We wish to be kept informed of the process of submissions and outcomes.  In general we do not wish to appear to speak to the submission at hearings, although we are open to invitation by Councils and District Health Boards to address representatives when required and when feasible.

We look forward to your response.


The Trustees

Physicians and Scientists for Global Responsibility New Zealand Charitable Trust


Media Release - 4 February 2013

Councils to consider the prohibition of commercial outdoor uses of GMOs in Northland and Auckland and requirement for consents under the RMA for outdoor field trials

An inter-council working party, representing all local authorities in Northland and Auckland, has recommended to member councils that they consider regulating the outdoor use of GMOs under the Resource Management Act (RMA) through provisions in their planning documents.

This would involve inserting objectives, policies and rules in existing district plans in Northland and in Auckland Council’s new Unitary Plan prohibiting the release of genetically modified organisms (GMOs) to the environment and making field trialing of GMOs a discretionary activity, subject to strict liability conditions for any environmental or economic harm that may eventuate.

The Inter-council Working Party on GMO Risk Evaluation and Management Options comprises the Far North, Kaipara and Whangarei District Councils and Auckland Council. Northland Regional Council is a member but did not participate in the project. The Working Party has produced draft planning provisions, a section 32 evaluation supporting those provisions, and a legal opinion from Dr Royden Somerville QC.

The section 32 evaluation is a requirement under the RMA to show why the proposed provisions are necessary to achieve the purpose of the Act and that they are the most appropriate, efficient and effective to achieve that purpose. The evaluation is also required to take into account the costs and benefits of the proposed provisions and the risk of acting or not acting if there is uncertain or insufficient information about the subject matter.

The Working Party has carried out a thorough evaluation of the necessity for regulation of GMOs at a district and/or regional level, in addition to national regulation under the Hazardous Substances and New Organisms Act (HSNO), over an extended period of 10 years.

This evaluation has confirmed there are potentially significant risks to local government and their communities from outdoor use of GMOs, including environmental, economic and socio-cultural risks. There is also considerable uncertainty (including scientific uncertainty) and lack of information about those risks. There is a lack of scientific agreement on the long term effects of releasing GMOs into the environment and a lack of information on long term environmental consequences. There is uncertainty and disagreement as to the short and long term economic benefits and dis-benefits from GMO crops and animals. And there are different cultural views as to the appropriateness of GM technology and GMOs, particularly from Maori.

In addition, the potential adverse effects of releasing GMOs into the environment could be significant – including possible major (and long term) harm. Moreover, these effects could be irreversible. Once released to the environment it is, in most instances, impossible to eradicate such organisms. They are, in effect, there for ever, whatever the consequences.

Against these risks, significant deficiencies in the national level regulation of GMOs have been identified. A key gap is that there is no liability under HSNO for damage arising as a result of an activity carried out in accordance with an approval from the national regulatory body, the Environmental Protection Authority (EPA). Nor is there any requirement under HSNO for applicants to prove financial fitness or provide bonds in order to recover costs should damage occur.

Thus, affected parties, including existing primary producers and councils, will tend to bear any costs arising from unexpected events and ineffective regulation of GMOs. Given the experience overseas of widespread contamination of non-GMO crops and rapid development of herbicide resistant pests and weeds, these costs could be considerable.

In response to the risks and associated uncertainties, along with community preferences for a precautionary approach expressed in the Colmar Brunton survey commissioned by the Working Party in 2009 and in public submissions to, and lobbying of, councils in Northland/Auckland, the section 32 evaluation has concluded that a strong precautionary approach to the release of GMOs to the environment is warranted. Such an approach is legitimised by, and indeed inherent to, the RMA. However, at the national level, HSNO makes the exercise of precaution a matter for the EPA’s discretion. The EPA is required only to consider the necessity for caution.

In accord with a strong precautionary approach, the section 32 evaluation supports the prohibition of releases of GMOs to the environment and the requirement for consent as a discretionary activity for GMO field trials. The section 32 analysis also supports provisions that set strict liability rules for potential economic and environmental harm, to the extent possible, and the requirement for bonds and proof of financial fitness.

However, the section 32 evaluation acknowledges the desirability of keeping future options open, and thus supports an adaptive risk management approach that would enable on-going review of prohibiting the release of GMOs, and the change of activity status to discretionary should new information come available, or scientific consensus be achieved, that shows that the benefits of releasing a particular GMO, or class of GMOs, outweigh the risks for the Northland/Auckland region.

Such a precautionary approach to risk management is supported by the courts. In particular, Coromandel Watchdog of Hauraki Inc v Chief Executive of the Ministry of Economic Development (CA285/05 2007) examined the appropriate use of the prohibited activity status in planning documents. In this case the Court of Appeal held that prohibiting an activity could be appropriate when a planning authority has insufficient information about an activity and wishes to take a precautionary approach, even though it does not rule out the possibility of that activity being permitted in the future when further information may become available.

The draft plan provisions are in the form of a plan change to councils’ RMA planning documents. The provisions are in a generic form that can be adapted to each council’s particular plan should it choose to undertake such a plan change. The provisions apply to land uses and to use of coastal waters. The plan provisions relate only to outdoor uses of GMOs, either releases to the environment or outdoor field trials. They do not include the use of GMOs in contained facilities, such as hospitals, universities, or research institutions, nor to medicines or food products that do not contain viable GMOs.

The documentation will now be referred to member councils on the Working Party for decisions on how to proceed from here. Should a decision be made to include provisions in council’s planning documents, further consultation is required prior to publically notifying any changes.  

Dr Kerry Grundy, convener of the Working Party, states:

“The collaborative approach to the issue of GMOs in the environment undertaken by local authorities in the Northland and Auckland regions has been a cautious yet responsible way to proceed with this contentious and complex issue. It is an excellent example of local government working together to address common concerns raised by their respective communities.

The comprehensive evaluation that has been undertaken over a long period of time, and the documentation produced as a result of that evaluation, provides a robust and comprehensive examination of the issue of GMOs in the environment, including both the risks arising from the outdoor use of GMOs and options to manage those risks.

The documentation provides councils on the Inter-council Working Party on GMO Risk Evaluation and Management Options with sufficient information to make an informed decision over management options for outdoor uses of GMOs and sufficient analysis and support to proceed with a change to district and/or unitary plans to manage GMOs should councils decide to undertake such an approach”.


For further information please contact Dr Kerry Grundy, Convener of the Inter-council Working Party on GMO Risk Evaluation and Management Options, (09) 430 4200, This email address is being protected from spambots. You need JavaScript enabled to view it.. The full documentation is available on Whangarei District Council’s website at   



[3] Former GE Canola Trial Sites Audit Reports, Department of Primary Industries, Parks, Water and Environment,

[7] Glyphosate is manufactured in different solution strengths, with various adjuvants (agents) under many tradenames - Accord, Aquaneat, Aquamaster, Bronco, Buccaneer, Campaign, Clearout 41 Plus, Clear-up, Expedite, Fallow Master, Genesis Extra I, Glyfos Induce, Glypro, GlyStar Induce, GlyphoMax Induce, Honcho, JuryR, Landmaster, MirageR, Pond-master, Protocol, Prosecutor, Ranger, Rascal, Rattler, Razor Pro, Rodeo, Roundup, I, Roundup Pro Concentrate, Roundup UltraMax, Roundup WeatherMax, Silhouette, Touchdown IQ - by include Bayer, Dow Agro-Sciences, Du Pont, Cenex/Land O’Lakes, Helena, Monsanto, Platte, Riverside/Terra, and Zeneca.

[8] ‘Glyphosate commercial formulation causes cytotoxicity, oxidative effects, and apoptosis on human cells:  differences with its active ingredient’, Chaufan et al Int J Toxicol. 2014 Jan 16. Epub, 16 January 2014, PMID: 24434723.

[9] Samsel et al, Entropy 2013, 15(4), 1416-1463; doi:10.3390/e15041416

[10] ‘Determination of Glyphosate residues in human urine samples from 18 European countries’, carried out by Medical Laboratory Bremen, Germany,

[12]‘Background document for development of Fluoride in Drinking-water’ © WHO 2004

[13] Prepared by Declan Waugh BSc CEnv MCIWEM MIEMA MCIWM Environmental Auditor and Strategic Advisor on Risk Assessment and Management

[17] For background material see

[20] ‘Oil: a risky business’ NZ Herald, 18 January 2014,

[21] and click on Hydraulic Fracturing.

[25] ‘Soybean susceptibility to manufactured nanomaterials with evidence for food quality and soil fertility interruption’, 2012,  (A)

‘UCSB Scientists Demonstrate Biomagnification of Nanomaterials in Food Chain’

[28] ‘Plant nanotoxicology’, Karl-Josef Dietz and Simone Herth,

[29] Mangere; Guidelines for the Safe Application of Biosolids to Land in NZ, August 2003; The Cost-Benefits of Applying Biosolid Composts for Vegetable, Fruit and Maize/Sweetcorn Production Systems in NZ 2004


[30] ‘Electromagnetic and radiofrequency Fields Effect on Human Health’ American Academy of Environmental Medicine,

[31] ‘Public health implications of wireless technologies’ (Sage and Carpenter, 2009),

[33] The David Suzuki Foundation, ‘Electromagnetic Radiation and Fields’ on