Publications & Resources

In 2019 the Soil & Health Association and PSGRNZ released the joint paper Aotearoa New Zealand Policy Proposals on healthy waterways: Are they fit for Purpose? Our white paper highlighted a critical gap in the Government’s Action for Healthy Waterways proposals.

We sent submissions into the related consultations, and sent out press releases to all media. The concerns expressed in that 2019 paper were not covered by the media, despite the fact that a major government consultation was underway.

Seven years ago, we discussed at length that a freshwater policy cannot credibly protect waterways for future generations if it did not have a systematic way to identify and investigate significant chemical contaminants.

The Government was prepared to discuss sediment, bacteria and nutrients. There were measures (called attributes) for nitrogen, phosphorus, dissolved oxygen, E. coli, sediment, periphyton, cyanobacteria, macroinvertebrates and fish communities which were subsequently incorporated into the National Environment Standards for Freshwater framework - the NES-FW.

What the proposed new standards did not build in, was an equivalent national architecture for anthropogenic chemical contaminants from urban, industrial and agricultural sources.

Despite our best efforts (and we were aware that a wider public were also sending their chemical pollutant concerns into the committee) the issue ‘was disappeared’. The Ministry’s Summary of submissions, published in May 2020, responsible for summarising 17,500 submissions, only mentioned chemical pollution fleetingly. The document noted calls to investigate ‘emerging contaminants’ because of their implications for human and ecosystem health, and elsewhere records concerns about chemicals and emerging contaminants in stormwater and drinking water.

It isn’t just us. Over this same period, Parliamentary Commissioner for the Environment Simon Upton has repeatedly raised these concerns - including at the highest levels. His reports and papers in 2019 2020 2021 2022 2026 are testament to a sustained effort to improve New Zealand’s environmental knowledge and reporting systems. Yet remarkably little seems to change.

The problem, seven years later in late 2026, is that several parliamentary Bills which claim to improve environmental stewardship, continue to fail to address the problem - the gap - that we identified so many years ago. If a government agency does not specifically require that a process is followed, and then also fund the work so that it can be done - it will not be done.

Environmental Reporting Amendment Bill 321-1 - 20/8/2026 PSGR Submission to Select committee.
Natural Environment Bill 234-2 - 13/2/2026 PSGR Submission to Select committee.
Hazardous Substances and New Organisms Amendment Bill (304-1) – 3/6/2026 PSGR Submission to Select committee.

At every opportunity, we have highlighted the risks. When we cannot know what is happening, we cannot stop it! We have highlighted the problems that arise when higher-level legislation fails to establish adequate frameworks requiring officials to detect, monitor and investigate chemical contamination. Without those frameworks, agencies may have no systematic process for determining whether industrial chemicals, agrichemicals, wastewater contaminants or other human-made substances are contributing to the degradation of a groundwater source, lake or river, and then feeding that knowledge back into regulatory decisions.

The government had commenced a work programme in 2022 in response to the PCE’s eight recommendations, outlined in his 2022 paper: Environmental reporting, research and investment. Do we know if we’re making a difference? But, even though it was a National Party 2023 election manifesto, by 2024, the programme was to all appearances, discarded:

‘I am refusing your request in full under section 18(e) of the Act as the information requested does not exist or, despite reasonable efforts to locate it, cannot be found. … there is currently no work to establish a nationally consistent monitoring framework for anthropogenic synthetic chemical contaminants in freshwater.’

Currently, government monitoring is largely organised around the national environment standards for freshwater (NES-F) a relatively narrow set of established indicators and contaminants, including nutrients such as nitrogen and phosphorus, microbial indicators such as E. coli, sediment, and selected metals and other known contaminants. What is largely missing is a systematic framework for detecting and investigating the much wider range of synthetic chemicals entering the environment, including pesticides and their metabolites, PFAS, pharmaceuticals, plastic-associated chemicals, industrial chemicals and complex mixtures.

If we do not routinely look for these substances, it becomes very difficult to establish where they are occurring, at what concentrations, whether they are contributing to ecological degradation, or whether regulation needs to change.

This becomes particularly important at the level of the local receiving environment. Existing freshwater monitoring and national standards may tell council staff that a river, lake or groundwater body is degraded, but that does not necessarily provide them with the investigative framework needed to determine why.

Where the familiar indicators do not adequately explain the observed degradation, there is no sufficiently developed framework that guides officials towards a progressively broader suite of chemical testing based on plausible local sources and pathways.

That might mean looking beyond nutrients, E. coli, sediment and selected metals to pesticides and their metabolites, PFAS, pharmaceuticals, plastic-associated chemicals, industrial chemicals, wastewater contaminants and, ultimately, relevant mixtures.

We raised this issue in 2019, when the government had $221 for freshwater improvement, and we (and all the groups that supported our paper) were ignored.

The critical missing step is therefore the bridge between detecting degradation and investigating causation. A functioning environmental-health system should enable an unexplained signal of harm to trigger progressively more sophisticated investigation, identify plausible contaminants and sources, and feed those findings back into monitoring, regulation and pollution prevention. Without that capability, we can know that a receiving environment is degraded while remaining remarkably poorly equipped to discover what is degrading it.

As of 2026 we have no Ministry for the Environment. We have a Secretary for the Environment (see Environment Act 1986, part 2). It is unclear whether that Secretary has the authority and resources to undertake the important work that is required to bring attention to the challenge from anthropogenic, manmade synthetic chemical pollutants.

Keep an eye out for ta response to this Official Information Act request NGOIA162 / 26-OIAD-02614. Hopefully we might find out a little more on this issue.

More information is available on a related Op Ed: Labour & National had $221 million for Freshwater Improvement. They didn’t ask about the Chemicals. New Zealand keeps rewriting environmental law without building the science frameworks to detect chemical harm. (September 2, 2026)

These fantastic organisations supported our 2019 white paper: Aotearoa New Zealand Policy Proposals on healthy waterways: Are they fit for Purpose? (2019) Published by: The Soil and Health Association of New Zealand and Physicians and Scientists for Global Responsibility Charitable Trust New Zealand Wellington, New Zealand Cover Image: N.Thamm ISBN (digital) 978-0-473-50130-3

20 August 2026

Ministry for Primary Industries Official Information Act Request No. OIA26-0675

Department of Conservation Official Information Act Request No. OIAD-9589

What is happening?

DOC has begun a programme to vaccinate approximately 300 core breeding birds from some of New Zealand's most threatened native species against H5N1 avian influenza. These include kākāpō, takahē, tūturuatu/shore plover, kakī/black stilt and kākāriki karaka/orange-fronted parakeet. This is a significant intervention because these are small, endangered populations and some of the birds are extremely important to the survival of their species.

Why are we asking questions?

DOC publicly described its 2024–2025 vaccination trial as showing that vaccination was 'safe and effective' and would help protect these birds from H5N1. But the trial did not expose vaccinated birds to H5N1. It measured antibody responses as a proxy for expected protection, and the trial report itself stated that overall efficacy would not be known until natural exposure occurred.

The vaccine being used now is not the vaccine that was trialled.

The threatened-bird trial used an H5N3 vaccine, Poulvac Flufend (A009733). The approximately 300 birds in the 2026 programme are instead to receive a different H5N2 vaccine (A012218). The earlier threatened-species trial therefore cannot itself establish the safety or efficacy of the product now being administered to these birds.

‘Highly pathogenic’ does not mean every infected species will suffer high mortality.

Pathogenicity concerns the capacity of a virus to cause disease. Different bird species can experience very different disease severity and mortality. The important conservation question is therefore not simply whether H5N1 is classified as HPAI, but what evidence shows that each of these endangered species faces a sufficiently serious risk of disease, death or population decline to justify intervention.

What triggered vaccination?

DOC has described the detection of H5N1 in migratory seabirds in Australia as a “trigger to start vaccinating” endangered New Zealand birds. But neither MPI's One Health document nor the related Cabinet paper identifies a published threshold for moving from preparedness into vaccination. The unanswered question is: what risk-benefit assessment showed that this trigger justified vaccinating these particular populations?

Vaccination itself is not risk-free.

These birds must be captured, restrained and injected, potentially repeatedly if boosters are required. Some free-living birds may then be difficult to recapture and monitor. The risk calculation therefore has two sides: the risk posed by H5N1 to each species versus the known and uncertain risks associated with intervention.

There are important unanswered questions about the original trial.

The published material does not provide the complete underlying numbers showing how many birds of each species were actually vaccinated, subsequently tested and followed over time. H5N1-specific HI testing was undertaken only in takahē, and chicken-derived thresholds were used to infer expected protection.

What are we asking DOC and MPI to disclose?

The OIA requests seek the underlying trial data; deaths, adverse events and longer-term outcomes; species-specific evidence of H5N1 risk; the scientific basis for extrapolating antibody responses to protection; the evidence supporting use of the different H5N2 vaccine; the expected booster regime; and the records showing who decided to proceed, according to what criteria, and how the programme was funded. MPI's own documentation for the H5N2 product says “Full efficacy and potency data is pending” and “Duration of immunity is not established.”

The central message:

This is not an argument against protecting endangered birds or against vaccination in principle. It is an argument for getting the risk assessment right. When an intervention involves core breeding animals from critically endangered species, the evidence supporting both the expected benefit and the risks of intervention should be transparent, species-specific and available for independent scrutiny before further intervention occurs.

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SCIENCE, STEWARDSHIP & SCALABILITY?

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We welcome your use of this resource but please cite:

PSGRNZ (2026) Reclaiming Health: Reversal, Remission & Rewiring. Understanding & Addressing the Primary Drivers of New Zealand’s Metabolic & Mental Health Crisis. Bruning, J.R., Physicians & Scientists for Global Responsibility New Zealand. ISBN 978-1-0670678-2-3

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In conclusion, substantial evidence indicates that current dietary guidelines have not stemmed rising rates of metabolic and mental disorders and, in several respects, may be contributing to the progression of illness. Health is complex, multifactorial, and dynamic. As defined by the World Health Organization:

Health is a state of complete physical, mental and social well-being and not merely the absence of disease or infirmity.[1]

The onset of multimorbidity at earlier ages is strongly associated with poorer long-term outcomes. Rising rates of multimorbidity, alongside equity in medication prescribing, are not proxies for improved wellbeing or quality of life.

This Report demonstrates that New Zealand’s health policy has rested on outdated assumptions while nutritional and metabolic science has advanced. Current Ministry of Health positions, echoed by government-aligned organisations, stand in sharp contrast to an expanding body of evidence showing that foundational dietary and supplementary approaches can reverse or mitigate many metabolic and neurological conditions, improving functionality, wellbeing, and quality of life.

Encouragingly, change is already underway. Case and cohort studies consistently show that substantial reductions in refined carbohydrate intake are associated with improvement, remission, and in some cases reversal across a wide range of metabolic and brain-related conditions.[2] [3] There is increasing consensus that compulsive overconsumption of refined carbohydrates, particularly in the form of ultra-processed foods, constitutes a form of substance-use disorder. Health coaching, peer support, and community-based programmes can facilitate dietary change and, in doing so, reduce the burden of metabolic and neurological disorders as well as pharmaceutical dependence.

Dr Jen Unwin, co-partner of the UK clinic that has pioneered approaches to reversing metabolic syndrome, reducing prescribing rates, and improving mental health outcomes, has described counselling, coaching, and support as ‘fantastically cheerful medicine’. Yet conventional therapeutic frameworks do not treat long-term dietary change as a clinical intervention in the same way pharmaceutical treatments are regarded.

The protection and promotion of health require officials to remain abreast of contemporary science concerning the central role of diet and nutrition in metabolic regulation, hormonal balance, and homeostasis. Vulnerable groups, including infants, children and adolescents, pregnant women, and those with elevated metabolic risk, have received insufficient attention. Indeed, agencies currently lack a clear understanding of what constitutes optimal nutrition by age and life stage. Government bodies have consistently failed to examine the relationships between diet quality, nutrient insufficiency, and the physiological demands imposed by age, sex, ethnicity, genetic variability, socioeconomic context, pregnancy, and inflammatory status.

Historic alignment with international dietary frameworks used in Australia, the United States, and Nordic countries has not succeeded in halting or reversing the rise of prediabetes, diabetes, metabolic syndrome, or mental illness. In the decades following the adoption of current guidelines, multimorbidity in younger age groups has increased markedly. Current policy frameworks emphasise the LDL cholesterol marker, minimise the importance of key macronutrients, fat and protein, and fail to link micronutrient sufficiency with optimal physiological function and resilience.

Public-good research in nutrition science, including the investment required to update regulations and policies through transparent reviews of the scientific literature, has been neglected, deprioritised, and underfunded. As a result, independent scientists that can challenge current assumptions are rare, and government policy remains largely silent on the carbohydrate–insulin pathway and insufficiently responsive to individual metabolic risk.

The technology to detect elevated risk for prediabetes is readily available, and the capacity to screen for nutrient deficiencies in people presenting with mental-health conditions is well established. Yet these interventions remain underutilised, restricted, or unrecognised. Over the same period, funding for pharmaceutical access has expanded, while research into drug risks and adverse effects has been comparatively underfunded. Drug trial data are difficult to access, if not opaque, and governments have not provided adequate funding to independently evaluate industry claims or to systematically assess harms alongside benefits.

In these knowledge gaps, officials appear disproportionately focused on potential risks associated with nutritional supplements, despite long histories of safe use and contradictory evidence, while adverse drug risks are largely left to voluntary disclosure by manufacturers. This reflects a deeper contradiction: the Ministry of Health has the authority to set clinical limits for nutrients, yet is not positioned as an authority on optimal nutrition or its role in sustaining metabolic and mental health.

Suboptimal diets and nutrient insufficiencies amplify risk across a broad spectrum of chronic conditions, including metabolic syndrome and complex multimorbidity, yet when knowledge is absent or incomplete, clinicians, families, and patients are denied meaningful choice. Informed consent cannot be achieved when upstream dietary options are neither explained nor endorsed.

This Report, together with the forthcoming companion report on micronutrients and mental health, demonstrates that a longstanding governance culture has placed carbohydrate science, the carbohydrate–insulin model, and nutritional sufficiency outside the scope of formal health policy for decades. Without system-wide correction, continued institutional reticence and gaps in nutritional understanding will perpetuate poor policy and poor outcomes.

There is, however, strong cause for optimism. Current metabolic and mental-health trends are not inevitable. They are reversible. With evidence-based, nutrition-centred health policy, the trajectory of chronic disease in New Zealand can be changed, and health reclaimed. This Report sets out practical pathways to address the primary drivers of the metabolic and mental-health crisis and to reclaim health.

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REFERENCES

NB: Number order differs from the original Reclaiming Health publication (PDF).

[1] World Health Organization. Health and Well-being. https://www.who.int/Data/Gho/Data/Major-Themes/Health-and-Well-Being

[2] Zheng, Q., Gao, X., Ruan, X. et al. (2025) Are low-carbohydrate diet interventions beneficial for metabolic syndrome and its components? A systematic review and meta-analysis of randomized controlled trials. Int J Obes DOI:10.1038/s41366-025-01822-5

[3] Athinarayanan SJ, Roberts CGP, Phinney SD et al. (2025). Effects of a continuous remote care intervention including nutritional ketosis on kidney function and inflammation in adults with type 2 diabetes: a post-hoc latent class trajectory analysis. Front. Nutr. Sec. Nutrition and Metabolism, Vol 12 – 2025, DOI: 10.3389/fnut.2025.1609737

PSGRNZ is currently publishing a series of Substack articles examining the regulation of RF-EMF in New Zealand and the growing scientific debate surrounding non-thermal RF-EMF exposures. The articles argue that the prevailing consensus position is increasingly difficult to reconcile with the expanding body of experimental, mechanistic, and observational research. They also examine whether more scientists internationally are now drawing attention to potential risks from non-thermal exposures than are actively asserting that such exposures pose no health risk.

EMF Sensitive? You May Not Be the Outlier You Think You Are

Part 1. An intro to New Zealand regulatory frameworks; why your concerns are outside the framework; and how EMF radiation regulation came to differ so much from toxic chemicals regulation.

A palpable under-representation of public health expertise.

Part 2. A committee weighted toward policy, monitoring standards and compliance, not comprehensive health risk evaluation.

The EMF Problem: RF Radiation Governance Without Democratic Risk Assessment.

Part 3. How ICNIRP became the central organising authority for RF-EMF safety standards across much of the world despite the absence of modern environmental public health risk assessment frameworks.

EMF Risk Blindspot: The role of modulation in signal interaction

Part 4. Voltage-Gated Ion Channels are like electrically controlled floodgates in the body’s communication network. Calcium is a central message carrier flowing through those gates.

The Wired and Unwell Cascade.

Part 5. The science linking wireless radiation to brain and nervous system harm.

RF-EMF: Three Biological Pathways, One Upstream Driver

Part 6. Different pathways disturb different oscillators but ultimately affect the same biological timing network.

We welcome your use of this resource but please cite:

PSGRNZ’s proposals for reform involves the implementation of high-level strategic science, regulatory and science system shifts, in addition to community and practitioner led wrap-around policies that directly support people in the short-term to pivot long-term to dietary habits that support metabolic health.

PSGRNZ broadly supports Professor Grant Schofield’s proposal:[1]

Investing in prevention: A minimum 15% of the health budget will be allocated to chronic disease prevention and 5% to mental health services.
Reforming food policy: Stronger nutrition labelling, reduced unhealthy food marketing, and ultraprocessed food tax measures.
Reducing medication reliance: Encouraging ‘social prescribing’ so GPs can refer patients to exercise, nutrition support, and mental health therapy before medication.
Expanding public health workforce: Training more health coaches and lifestyle medicine experts to support behaviour change.
Ensuring accountability: A National Health Reform Taskforce with executive powers will monitor progress, report on key health indicators, and adjust strategies as needed

In addition to the Schofield Proposal, PSGRNZ propose the following:

[I] DIET FIRST APPROACHES IN LOCAL COMMUNITIES.

Implement practitioner and community-led dietary approaches that recognise individual susceptibility to hyperglycaemia and hyperinsulinemia in response to high-glycaemic and refined carbohydrate intake (cumulative carbohydrate burden), and that address the challenge of food addiction, which may co-occur with and reinforce chronic high refined carbohydrate intakes.

1. Formal recognition that so-called prediabetes (HbA1c 39–46 mmol/mol; 5.7–6.4%) is more accurately described as early type 2 diabetes mellitus (Zinn, 2025). HbA1c values in this range reflect impaired blood glucose regulation and represent a precursor state to metabolic syndrome, conferring increased long-term health risk.

2. The right to information on the dietary carbohydrate and consequent blood glucose burden for that individual. From childhood onwards, New Zealanders have the right to be informed of the combinatory role of free sugars and dietary carbohydrates in creating the metabolic conditions which underlie prediabetes, diabetes and which are associated with common chronic metabolic and brain-related conditions. That individual has the right to regular testing to assess that individual’s unique predisposition to the risk of unstable blood glucose, elevated triglycerides and elevated insulin.

3. Right to information and informed consent: Patients must be provided with clear, comprehensive information about the likely progression of common medication pathways associated with metabolic syndrome, inclusive of diabetes. Informed consent should be explicitly strengthened to ensure that patients understand the potential for a progressive cascade into multimorbidity following diagnoses such as prediabetes and diabetes. This requires that patients are fully briefed on the side effects of medications that are likely to be co-prescribed over the course of treatment for metabolic and psychiatric conditions, including the risks of drug–drug interactions.

4. Expand health coaching across general practice, integrating a three-pronged approach (Zinn et al. 2025[2]): Whole food, carbohydrate reduction; a health coach, behaviour-change-based delivery approach; and community- or peer-based initiatives to reduce hyperglycaemia and hyperinsulinemia. Health coaches combine holistic and flexible individual- and community-based nutrition education to support patient dietary transitions away from patterns that provoke hyperglycaemia and hyperinsulinemia. Health coaches incorporate food addiction education and counselling to support patients to adopt behavioural and psychological strategies to optimise nutrient intake and health outcomes.

Recent New Zealand findings corroborate with international evidence that the three-pronged health coach model results in meaningful patient outcomes, improves health equity, and reduces medical prescribing. A small number of early-adopter New Zealand primary care practices have integrated qualified health coaches, a model that can be expanded.[3] [4]
Expand PHO health coach services to integrate the three-pronged approach.
Refer all patients with HbA1c 39–46 mmol/mol+ for health coaching to support long-term reduction in chronic elevated blood glucose levels.

5. Offer subsidised, Pharmac funded continuous glucose monitors (and training) for young people under 25 after diagnosis of prediabetes or diabetes, including T2DM. Automatic provision for the under 25 age group with the choice of access to a CGM device for an initial six-month period.

6. Expand care of dental and general practitioner services to young people under 25 (this aligns with the NZDA’s call to increase affordability of access to dental care). PSGRNZ echo select proposals by the New Zealand Dental Association (NZDA), Roadmap Towards Better Oral Health report which recommended expanding care to young adults and the implementation of dental service models to meet the needs of local communities and high-need population groups.

Free doctors and dental visits to young people under the age of 25.
That pharmacy charges to patients for prescriptions issued by a dentist should be the same as those for prescriptions issued by a medical practitioner in primary care.
That patients attending a dentist should have access to funded laboratory services for histology and routine blood tests on the same basis as primary care.

7. Offer high-dose multinutrient supplementation as an option as an adjunctive, first-line treatment for a spectrum of psychiatric conditions that would automatically be diagnosed as requiring prescription drugs and health coaching as an integrative wrap-around support framework. The Hardy DEN product, and future similarly structured products is sufficiently safe to be offered for retail sale as a general nutrient by healthcare practitioners. (Pharmac funding for the under-25 age group and for individuals who receive work and income benefits).

Automatically enrol people eligible for high-dose multinutrient supplementation, in health coaching as wrap-around, clinician led and community enhanced integrative support framework to enhance nutrient intake, address food addiction, and support the remission of metabolic and brain-related parameters for a period of two years.

8. Re-establish the original Ka Ora, Ka Ako programme. Ensure that meals are locally produced by community contractors. Amendments may include:

Review of lunch menus to: (i) ensure meals support optimal brain health; and (ii) substantially reduce high-glycaemic carbohydrate portions, given the strong likelihood that carbohydrates will dominate other meals and snacks throughout the day because they are the most affordable macronutrient.
Greater focus on waste reduction and management: implementation of recyclable or compostable packaging options and practices; utilizing more biodegradable packaging materials; improving communication around appropriate waste disposal methods; and enhancing provider’s recommendations for sustainable practices (Dey, 2025, p.244).

[II] EDUCATIONAL REFORM

9. Expand nutrition education across medical training: Encompassing functional nutrition (including the role of macro- and micronutrients in biological function, metabolic regulation, and the maintenance of cellular and neurobiological systems), including the role of nutrition not only in preventing deficiency, but in supporting health, and in reducing and reversing the biological and inflammatory drivers of chronic metabolic and brain-related illness.

Undergraduate level – with core, assessable nutrition competencies embedded within medical curricula.
Postgraduate level – including structured nutrition education within vocational training programmes and specialist colleges.
Professional organisations – increase the visibility and status of nutrition within professional bodies such as the Royal Colleges, including through formal competencies, accreditation standards, and continuing professional development (CPD) requirements.

10. Embed nutrition education throughout the school curricula. Improve the quality of nutrition education, incorporating recognition of the carbohydrate-insulin pathway, the specific role of micronutrients in human biological systems and in particular, brain health, and provide food addiction education and counselling alongside other forms of counselling services.

Preschool – food preparation and eating.
Primary – Embed stepwise nutrition education across health, science and wellbeing curricula so that students can gain an appreciation of nutrition’s role at the level of the mitochondria, the cell, an organ system, the gut microbiome and the brain. Educate children on the difference between craving refined sugars and starches and real (homeostatic) hunger, and the role of protein, fat and fibre in satiety.
Secondary – revise curriculums across biology, science and health so that the role of nutrition in sustaining and protecting animal/plant/human health is weighted at least as equivalently as genetic factors. Reintroduce compulsory nutrition and cooking education for years 7-9. Educate children on the difference between craving refined sugars and starches and real (homeostatic) hunger, and the role of protein, fat and fibre in satiety.
Tertiary – Increase content quality and pathways for research across health, medical and agricultural sciences. Course content to emphasise the role of nutrients in biological processes from the mitochondria, to cellular, to organ systems and the metabolism. For example, for psychology, nutrition may focus on brain health, for agriculture nutrition may focus on soil health, productivity and fertility, for health sciences and medicine nutrition can consider biochemical pathways to disease and health and the role of dietary nutrition in preventing mental and metabolic disease.

[III] INSTITUTIONAL & REGULATORY REFORM.

11. Alignment with some aspects of the Rebalancing our food system May 2024 report by the Public Health Advisory Committee (PHAC).[5] This supports increasing access to healthy foods. However, this report aligns with government dietary guidelines. Without a substantial policy shift it is likely that any policy shifts could prioritise access to healthy meat protein and healthy fats.

12. Expand access to laboratory testing services: New Zealand’s relatively small population size has resulted in a small group of laboratories who undertake the bulk of testing and privately funded testing must not be unduly restricted.

Expand publicly funded nutritional status testing for high-risk groups: vitamin D, vitamin B12, folate (B9), vitamin B6, copper and selenium. This includes the following categories of people diagnosed with a psychiatric and/or neurodegenerative condition: (i) under-25 year olds; and (ii) preconception and pregnant mothers; and (iii) Those with treatment resistant psychiatric illness; - diagnosed with depression, anxiety, schizophrenia, obsessive compulsive disorder, bipolar and/or ADHD; (iii) People diagnosed with dementia/neurodegenerative conditions.
Where a specific clinical pathway exists, expand testing for: (i) MTHFR polymorphism, (ii) CYP450 panel; (iii) Broader HLA safety screening; (iv) Monogenic diabetes (MODY) genetic testing.
Expand high-sensitivity C-reactive protein (hs-CRP) testing. Hs-CRP (>3 mg/L) can be used in routine clinical practice to identify primary prevention individuals at increased inflammatory risk as long as the patient is not acutely ill.
Remove barriers to enable the general public to independently request and self-fund laboratory serum testing directly through their medical practitioner. Access to such testing should not require specialist referral for approval of individual tests or test panels, nor require disclosure of personal information to laboratories beyond that included in the clinician’s test request.

13. Provide Pharmac funding for high dose multinutrient supplements for the under-25 age group and low-income, at-risk groups.

MoH/Medsafe can reverse their general sale medicine decision for the Hardy’s multinutrient product and that product can be generally available as a retail multinutrient supplement from health practitioners. Products with equivalent ingredients must not be classified as a general sale medicine.
Pharmac can fund the Hardys DEN products under the multivitamin preparation category for (i) the under-25 age group; and (ii) preconception and pregnant mothers; and (iii) Treatment resistant psychiatric illness; - diagnosed with depression, anxiety, schizophrenia, obsessive compulsive disorder, bipolar and/or ADHD; (iii) doctors can have discretion to expand use of the DEN product to other categories including for the prevention or slowing of neurodegenerative disorders for a period of two years.

14. Implement a pathway to regulatory reform that recognises that micronutrients have therapeutic potential and that they can be consumed at upper levels that are safe. The Medicines Act 1981 does not permit micronutrients to have therapeutic potential. This is not supported by science. The role of higher dose micronutrients has been ignored in government policy. After thirty years of the status quo, a pathway to reform must ensure open and collegial scientific and health-based engagement prior to the Ministry of Health taking action to draft legislation. This is to ensure that future legislation does not automatically adopt a toxicological perspective which could then rule important considerations out of scope during select committee consultation processes.

Regulations can be amended through Orders in Council (secondary legislation):

The terminology in the Dietary Supplements Regulations 1985 can be amended to replace ‘maximum daily dose’ with ‘recommended daily dose’.
The Medicines Regulations 1984 Schedule 1, Part 1 can be altered, removing lithium as an exclusively pharmaceutical medication.

15. Guiding principles for all health legislation:

Primum non nocere – First do no harm.
Evidence based. This includes (i) regular reviews and public reporting of the changing evidence base for safety and risk, (ii) Including evidence of safety and efficacy by age, gender and health status held by governments and industry and updates in the scientific literature; (iii) the obligation that all medical drug and device information is linked to the trials information and data that are claimed to support the safety and efficacy of the medical drug or device.
Require signed informed consent.
Match regulation to the biological risk.
Prevention through empowerment. People can read and review studies to establish whether dietary changes, dietary supplements and medical drugs and devices are beneficial or risky for them.

[IV] SCIENCE SYSTEM REFORM

16. Disestablish the Ministry of Business, Innovation and Employments’ (MBIE) control over science and technology funding. The decline of human and environmental health research, research to monitor and evaluate New Zealand resources and infrastructure, and the decline of basic research in agriculture, has mirrored the domestic pivot to prioritise innovation.

17. Establish a Ministry of Science, Research and Technology. Overarching principle for research funding revolves around the long-term stewardship, or kaitiakitanga, of New Zealand, her people and environment. Devote fully 50% of New Zealand’s science, research and technology budget to public good research. This involves shifting research that demands an innovation output to instead reposition innovation as one element or outcome that is embedded within the research, science and technology platform, rather than the current situation which positions innovation as the north star of New Zealand’s research architecture.

18. Establish a multidisciplinary environmental health institution in a New Zealand region which is tasked to drive chronic disease prevention and remission through the advancement of knowledge relating to the dietary, nutritional and toxic drivers of metabolic and mental illness. The institution board will include experts in nutrition, metabolism, nutritional psychiatry, nutrigenomics, endocrinology, inflammatory and biomarker assessment, epidemiology, toxicology and diet, who have a demonstrated research record in these sectors relating to chronic disease prevention.

19. The environmental health institution board will establish the policy and work programme for the institution. Research, which can complement global research trajectories, will include anthropogenic exposure monitoring and assessment of risks from man-made chemicals, heavy metals and radiation. This includes occupational, household, industrial, urban and agricultural exposures, research to identify the additive and synergistic health risks from the food additives,[6] plastics, electromagnetic field radiation, pesticides, common drugs and low levels of chemicals in drinking water. The work programme will include the review and assessment of optimum micronutrient levels by age, gender and developmental stage. Aims will target increased recognition of health harms from poor diets,[7] [8] improved consumer knowledge through better labelling[9], improved school dietary choices[10] [11] and support the adoption of nutrient-dense diets across the population.[12] [13]

The quality of research will be ensured by rigorous reviews of the independent scientific literature where authorship, research methods and raw data is disclosed; and which take into account human difference (complexity and uncertainty) and biology. Evidence for research and policy can be drawn from structure and function studies to single cases, cohort studies and controlled trials.

20. The institution will be 50/50 funded by the health budget and the Ministry of Science. Ministers and political appointees, including chief science advisors will not direct funding trajectories. This institution will be based in Hamilton or Christchurch and affiliated with research across relevant academic institutions.

21. Environmental health institution to have independent powers to inform New Zealanders. The Institute will be tasked to independently support and inform communities, hospitals, the education sector and clinical practice to incorporate evidence-based nutritional and dietary education to reduce ultraprocessed food intake, increase wholefood intake, and optimise mental and metabolic health.

22. Innovation is recategorized as an element of research, not the key driver. For example, research funding can be allocated to co-design and development of healthy formulated foods with industry, development of screening and assays to identify harmful or toxic formulations. This could drive trust and promote consumer confidence in domestic and export markets. As a part of a recent project to reconfigure ultraprocessed foods to optimise human functioning, a group of researchers proposed a ‘Metabolic Matrix’ as a principle-based pathway which would revolve around protecting the liver, feeding the gut and supporting the brain.[14]

Conclusion: Reversing Surging Multimorbidity with 'Fantastically Cheerful Medicine.

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REFERENCES

NB: Number order differs from the original Reclaiming Health publication (PDF).

[1] Schofield, G. (March 2025). Health Reform in New Zealand. https://prekure.com/petition/#proposal

[2] See also discussion Part III, above. [Chapter 9, Chapter 10, Chapter 11].

[3] E.g. Health Coaches Australia and New Zealand Association (HCANZA).

[4] Zinn C, Campbell JL, Fraser L. et al. (2025) Carbohydrate Reduction and a Holistic Model of Care in Diabetes Management: Insights from a Retrospective Multi-Year Audit in New Zealand. Nutrients.17(24):3953.

[5] Public Health Advisory Committee. 2024. Rebalancing our food system. Wellington: Ministry of Health.

[6] Payen de la Garanderie M, Hasenbohler A, Deschamp N, et al. (2025). Food additive mixtures and type 2 diabetes incidence: Results from the NutriNet-Santé prospective cohort. PLoS Med 22(4): e1004570. DOI:10.1371/journal.pmed.1004570

[7] Abar L, Steele EM, Lee SK, Kahle L, Moore SC, et al. (2025) Identification and validation of poly-metabolite scores for diets high in ultra-processed food: An observational study and post-hoc randomized controlled crossover-feeding trial. PLOS Medicine 22(5): e1004560. DOI: 10.1371/journal.pmed.1004560

[8] Good KE, Parnarouskis L, Cummings JR, Gearhardt AN (2025). Adapting anti-tobacco messages to ultraprocessed foods: message framing's impact on attitudes toward the food industry. Obesity. 33(5):903-914. DOI: 10.1002/oby.24272

[9] Mackay S, Eyles H, Gontijo de Castro T, Young L, Ni Mhurchu C, et al. (2021) Which companies dominate the packaged food supply of New Zealand and how healthy are their products?. PLOS ONE 16(1): e0245225. DOI:10.1371/journal.pone.0245225

[10] Myers I (April 9, 2025). California Assembly committee advances bill to protect schoolchildren from harmful UPF. EWG News. https://www.ewg.org/news-insights/news-release/2025/04/california-assembly-committee-advances-bill-protect

[11] Trask S, Thornley S, Sundborn G. (2024). School-based learning about sugary drinks: possibilities and potential for curriculum approaches supporting health promotion in New Zealand. Health Education Research, 39(5)475–485. DOI: 39/5/475/7696174

[12] Starck, C.S.; Blumfield, M.; Keighley, T.; et al. (2021).Nutrient Dense, Low-Cost Foods Can Improve the Affordability and Quality of the New Zealand Diet—A Substitution Modeling Study. Int. J. Environ. Res. Public Health18:7950. DOI: 10.3390/ijerph18157950

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[14] Harlan TS, Gow RV, Kornstädt A, Alderson PW and Lustig RH (2023) The Metabolic Matrix: Re-engineering ultraprocessed foods to feed the gut, protect the liver, and support the brain. Front. Nutr. 10:1098453.

doi: 10.3389/fnut.2023.1098453

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For over 20 years the Physicians and Scientists for Global Responsibility New Zealand Charitable Trust (PSGR) has produced reports and submitted to government Bills and Inquiries.

We’ve been extraordinarily busy over the past 2 years with our work.

This Update aims to inform members and colleagues – and act as a go-to summary of our recent work.

2022 UPDATE - PDF

As well as our recent work All PSGR’s submissions are available to the public on our Submissions pages. In addition, we are now on LinkedIn, Twitter, Odysee & Instagram.

MEMBERSHIP

Please – without your support and membership PSGR cannot do this work. We’ve kept our fees deliberately low because your membership is important to us.

MOVING FORWARD 2022+

The PSGR recognise that the perspectives that have been expressed by the PSGR from 2020 onwards will not necessarily reflect the perspectives of all trustees and all members.

However, we sincerely hope that PSGR’s perspectives are more likely to reflect the perspectives of the majority of our membership and of collegial organisations – which represents a diverse quorum of inquiring minds.

We hope that we have demonstrated a consistency to our work, that reflects and upholds the principles reflected in 20 years of research, information communications and submissions to policy

Reports and Papers

Royal Commission

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