GLYPHOSATE. Twenty years of highlighting cancer risk (2022).

BACKGROUND - GLYPHOSATE ON FOOD PRODUCTS

Corporations look for new ways to utilise products that extends the product lifecycle and enables the product to be sold in different product categories and markets. This increases and sustains sales.

The herbicide glyphosate is no different. As a weed-killing herbicide, glyphosate was initially marketed to kill weeds before crop planting commenced. However, in 1996 the first glyphosate resistant soybean was released. This was the start of the pivot to spraying glyphosate herbicide, commonly known as Roundup, on food crops - soy, corn, canola, sugar beet and alfalfa (lucerne). Most genetically modified (GM) crops are herbicide tolerant. Plants can be 'stacked' permitting multiple herbicide mixtures to be applied on the growing food crop. Stacked traits may also include insect resistant traits. A product might have 2-5 traits. Much of the herbicide tolerant traits have been introduced to manage increasing herbicide resistance, in a chemical arms race. At no time do regulators consider the cumulative and combinatory exposures of all the herbicides and insecticides that increase dietary intake for these pesticides (pesticides include herbicides, insecticides and other biocides). The vast majority of genetically modified agricultural crops confer herbicide-tolerant (HT) traits.

In countries where HT crops are marketed, scientists have observed a reduction non-GM varieties as monocropping pushes smaller varietals out (and as farmers were litigated for replanting seeds that had cross pollinated naturally with the patented herbicide tolerant plants). Traditionally, farmers and seed specialists cross pollinated, often benefitting from hybrid vigour of the crossed, or hybridised seed and the traits; and the flexibility to select traits which suited local climates and soil types. Due to the expense of biotechnology development, once released, HT GM crops often become locked in for decades, while naturally bred cross-pollinated crops can respond more flexibly to shifting demand, and maintain better yields across the years to ensure that food supply reflects population needs.

In addition to the marketing of glyphosate as an application on HT crops, glyphosate is marketed as a desiccant, and permitted to be applied to a broad range of non-GM food and

beverage crops. Desiccant sprays are applied prior to harvest, so as to 'dry down' the crop and remove moisture. This activity explains the increasing levels of glyphosate in cereal products, including wheat, barley and oat-based products.

GLYPHOSATE IS A CASE STUDY OF A WIDER PROBLEM

It's important not to see glyphosate as an anomaly, but rather, an example of governance and regulatory systems that neglect to respond scientific norms that are generally accepted in industry research, such as identifying hormone level risks in drug development; or the exciting potential of omics and biomarker technologies). By deferring to industry sponsors (e.g. New Zealand and Europe) to supply the (confidential) science that that regulators consider as 'authoritative', and prioritise in risk assessment - regulators remain 'in the dark' about the wider scientific evidence.

In New Zealand, precaution sways in favour of retaining an unsafe pesticide on the market. Regulators can depend on modelling and industry data but are not required to review the scientific literature, nor require local scientific monitoring and research to feedback into the regulatory arena. While the precautionary principle is included in our legislation, the legislation is drafted in such a way that the principle is not prioritised. New Zealand's weak regulations result in dozens of pesticides in our soil, water and bodies, that are banned in Europe (see discussion part 5 of this paper).

This harms two ways - it hides the knowledge about human harm, as well as wider environmental harm. In both cases these 'activities' fail to assess the complex and often subtle impact on developmental organisms and the impact on intergenerational resilience following exposures.

20 YEARS OF WORK HIGHLIGHTING GLYPHOSATE'S CANCER-CAUSING POTENTIAL

PSGR has been concerned about dietary glyphosate for 20 years. In 2000 our trustees and members submitted to the New Zealand Royal Commission on Genetic Modification (RCGM). We advised, in 2000 on the association of glyphosate with non-Hodgkins' lymphoma, and of the risk to children. We discussed how protein expression might alter. Since that time we have consistently submitted to consultations, to draw attention to the risk from glyphosate when applied widely to food crops and in public places. For example in 2005 we were describing how glyphosate exposure can alter testes, and can modify DNA to produce DNA adducts, which arise after exposure to carcinogens.

In 2015 the International Agency for Research on Cancer (IARC) released a decision on the carcinogenicity of glyphosate. The IARC determined that glyphosate, and glyphosate-based herbicides definitely cause cancer in laboratory animals, and probably cause cancer in humans. Glyphosate was designated as a 2B carcinogen.

In 2015 the PSGR swiftly followed this decision with the release of a report: Glyphosate: A probable carcinogen. Our report draw attention to the increasing risk factors surrounding glyphosate-based herbicides and the problem of herbicide tolerant crops.

However, in August 2016, following the IARC finding the NZEPA released a 'Review of the Evidence Relating to Glyphosate and Carcinogenicity' as well as an accompanying Lay Review. This report was authored by a single author and peer reviewed by government scientists. No outside scrutiny occurred. This report was heavily criticised in an August 2017 Green Party paper, 'Public Health Concern: Why did the NZ EPA ignore the world authority on cancer?' (NB. A trustee of PSGR provided advice regarding the public and administrative law obligations of public officials, and co-author Jodie Bruning was invited to join PSGR following release of the paper). The Greens paper drew attention to the IARC protocol of using paper from the published and peer reviewed literature, and looking at the greater toxicity of the retail formulation, whereas the NZEPA review exclusively relied on industry data. PSGR, as well as New Zealand public health scientists, including cancer researchers and epidemiologists; a professor of law and Doctor Jane Goodall, placed statements of support on the paper. This was requested by the Green Party due to the controversial political environment surrounding glyphosate authorisation.

Then in 2018, public health scientists published the paper 'Carcinogenicity of glyphosate: why is New Zealand's EPA lost in the weeds? in the New Zealand Medical Journal (NZMJ).

The NZMJ paper called for the NZEPA review to be

'withdrawn and for the NZEPA to accept IARC’s conclusion that glyphosate is a probable carcinogen.'

The authors requested that steps were taken to ensure exposures are minimised, and expressed concern that current regulatory approaches might result in weak stewardship in future:

The issues discussed in this viewpoint have broader implications for future evaluations. In our view, these are the matters that warrant closer attention and, perhaps, remedial action: 1) lack of transparency about the relations NZEPA has with industry and management of conflicts of interest; 2) the implications of the Ministry of Health’s lack of confidence in NZEPA’s processes in relation to glyphosate; 3) the lack of clarity in NZEPA communications about the steps taken in the assessment of hazardous agents (which typically proceed from hazard identification to exposure assessment to risk characterization; these are not bundled together); and 4) the inappropriate application of “net benefit” thinking to the front end of risk management.

THE NEW ZEALAND ENVIRONMENTAL PROTECTION AUTHORITY

As of 2021, New Zealand's Environmental Protection Authority (NZEPA) has never conducted a comprehensive risk assessment of glyphosate, to balance the data supplied by the industry sponsor, and evaluate or triangulate this data in the scientific literature.

Instead of risk assessments, Regulatory agencies receive updated information from the chemical company sponsor as applications. This can involve completely new pesticides, or new ways to use a pesticide, such as when the NZ EPA permitted higher strength 600g/L glyphosate products not approved in safer jurisdictions to be released (discussed here on page 10) Regulatory agencies depend on similar submission processes from the industry 'sponsor' - whereby the industry selects and supplies the data for risk assessment. The public are then left on the back foot to contest this information, and regulators may, or may not elect to comprehensively review the literature on risk. However, in practice, literature reviews rarely occur.

It is of note that as of 2021, the sub-committee who would meet to committee tasked with deciding on whether there was new information on glyphosate (such as the IARC decision or the findings from US court cases) have never met to assess whether there was new information. It is noteworthy that the public health (including on cancer and epidemiology) expertise of the scientists who authored the NZEPA paper far outweigh the scientific knowledge of members of the sub-committee, in their expertise relating to the relationship of environmental chemicals with cancer, oxidative stress and toxicity.

CALLS FOR INFORMATION - A DELAYING TACTIC FOR RISK ASSESSMENT?

In 2021 PSGR responded to a 'Call for Information' by the New Zealand Environment Protection Authority (NZEPA). The PSGR's response illustrated the 'wicked problem' that has been driven by ongoing 'under-regulation' of the probable carcinogen glyphosate. The PSGR's response outlined the interconnected issues of weak regulation, herbicide resistance in weeds as a driver of herbicide contamination, and the failure of agencies to 'keep up with the science' - and instead constrain their perspective to narrow, technical perspectives that cannot address greater issues of contamination and risk - despite the fact that this content is richly illustrated in the scientific literature. Without paying attention to such factors, the NZEPA is unable to carry out the obligations required of them by their overarching legislation, which is the HSNO Act. The purpose of the HSNO Act obliges the NZEPA to

Purpose of Act: The purpose of this Act is to protect the environment, and the health and safety of people and communities, by preventing or managing the adverse effects of hazardous substances and new organisms.

The substantive submission may be easily accessed online and downloaded here. The content below, is an extract from the main submission.

In May 2022, the NZEPA released Glyphosate in Aotearoa New Zealand. Summary Report on the Call for Information.

The Call for Information demonstrates how regulators fail to make ethical judgements that relate to the evidence of toxicity and risk as stated in the literature by standing back and promoting debate and contestation. The EPA are using this technique to delay risk assessment of other controversial pesticides including neonicotinoid insecticides and on groups of aquatic herbicides, (many of which are not sprayed on water in Europe, and for example, metsulfuron-methyl, have not undergone formal risk assessment but are widely applied down New Zealand roadsides).

New Zealand scientists outside the agency have autonomy to research glyphosate and other so-called controversial pesticides, nor review the scientific literature (the funding scopes do not permit long term research projects). This leaves civil society contesting use of pesticides, and spray drift, in council chambers. However, with no 'authoritative' scientific expertise, councillors are more easily persuaded by staff to defer to the authority of the EPA.

This also happens during the submission process to the NZ EPA. EPA activities, such as the Call for Information consultation inevitably presents as a debate between the industry and the civil society (which includes lay public and more rarely, expert scientists). Consequently, EPA Summary Reports are presented as a he said-she said document and do not represent impartial scientific evaluation. This is how the EPA will then make such claims, for example, such as glyphosate 'helps manage resistance' (see page 23). There's no evaluation of the published scientific evidence presented to the EPA, such as the information regarding herbicide resistance that the PSGR had drawn attention to in our response to the Call for Information. Most scientific evidence presented by the public is not a requirement for consideration in their Methodology document, and is therefore frequently dismissed.

Therefor reports such as the Call for Information on glyphosate report, continues the pattern of the regulator taking evasive action to avoid discussing the evidence in the peer reviewed literature and the implications of international court cases, that substantially find in favour of the plaintiff.

Regulatory agencies work co-operatively to ensure their messages are consistent and co-ordinated, particularly when it comes to the most lucrative technologies.

Therefore, it was not surprising that the NZEPA released their May 2022 report, just after the European Commission May 10 decision to push out decisions on glyphosate to 2023.

The European Union decided classification of glyphosate as a carcinogen is not justified:

On 30 May 2022, ECHA’s Committee for Risk Assessment (RAC) agreed that the current harmonised classification of glyphosate should be retained (i.e. as causing serious eye damage and being toxic to aquatic life). Based on a wide-ranging review of the available scientific evidence, RAC concluded, as in 2017, that classifying glyphosate as a carcinogen is not justified. In June 2022, the Health and Environment Alliance (HEAL) published a report which argued that “the cancer studies provided by pesticide companies for the carcinogenicity assessment of glyphosate show the clear potential for the substance to cause cancer”. The Commission asked ECHASearch for available translations of the preceding to consider the HEAL Report and respond to it. ECHA’s response for available translations of the preceding confirms that all available data was properly evaluated, and that the conclusion reached is scientifically robust.

The EFSA December 2022 Pesticide Peer Review TC 80 demonstrates how secret industry studies, often decades old are privileged, while new information in the published scientific literature are excluded. The public cannot see or access the original studies. The paper A comprehensive analysis of the animal carcinogenicity data for glyphosate from chronic exposure rodent carcinogenicity studies, revealed that many studies dismissed by authorities as not showing harm, such as high tumour rates, indeed do.

Glyphosate is currently approved for use in Europe until December 2023.

CONCLUSION

The biggest determinant of the continued authorisation of glyphosate, and glyphosate-based herbicides on human food, and in public places are results following court trials. Regulatory activity over the past 20 years demonstrates that regulators act to legitimise the ongoing authorisation of products on the market. When new evidence on risk arises, or evidence on risk accumulates, this is pushed aside using various methods. We can see from the NZEPA's 2020 Methodology document that the act of keeping controversial scientific evidence arises through reliance on the sponsor to provide data, through the use of guidelines, protocols and modelling scenarios, and through the absence of requiring feedback from New Zealand scientists. There are no requirements that the NZEPA receives feedback either from scientists working in the New Zealand environment. In New Zealand there are no scientists charged with reviewing the science on glyphosate, and conducting laboratory studies, to verify and triangulate industry claims.

As we have discussed, the authorisation of 600g/L glyphosate underscores the NZEPA's position globally, as a weak regulator. This strongest strength glyphosate places farmers more at risk, as accidental/unintentional poisoning/contamination is commonplace (see also pages 15-17 on our Call for Information Submission). It is difficult for farmers to avoid contamination, no matter how cautious they are.

The example of glyphosate provides perhaps the most conclusive evidence of why the courts are the frontline of action of civic action demanding better stewardship, and/or demanding the withdrawal of controversial and harmful technologies from the market.

With courts at the front line of this debate, this infers, in a New Zealand context where comparatively little litigation is undertaken, that New Zealand will be slower to adjust to risk and take steps to ensure a safe space for the public and for New Zealand farmers.

PDF: PSGR 2015 REPORT

PDF: 2021 PSGR SUBMISSION TO THE NZEPA CALL FOR INFORMATION

EXTRACT: SUBSTANTIVE REGULATORY 'PROBLEMS' OUTLINED IN THE 2021 PSGR CALL FOR INFORMATION RESPONSE.

In this Call for Information (CFI), relevant questions have remained outside the scope, such as requiring information on spills and contamination, health conditions, herbicide resistance and mixtures commonly tank mixed with GBH formulations.
Weed resistance is a greater driver of herbicide pollution. Global pesticide use increased by 80% between 1990-2017.[1] Herbicide sales constitute 45% of chemical pesticide sales in New Zealand.[2] Increasingly harmful herbicides are applied to cope with increasing herbicide resistance.[3] [4]
Mixtures of herbicides are the ‘norm’, contaminating soils globally.[5] [6] [7] [8]
Tank mixing increases pressure on the environment. GBH formulations will be applied at the recommended rate and will be tank mixed with other herbicides.[9] One spray will have 2 or 3 times the amount of active ingredient applied, plus the adjuvants and organosilicon surfactants.
In order to combat resistance, different herbicide mixtures with different modes of action[10] are commonly applied. New Zealand may have over 12 glyphosate-resistant species.[11] Recent journal literature has been opaque concerning the extent of local glyphosate resistance.
European moves more swiftly to ban hazardous substances. The range of pollutants banned in Europe released into air, water and soil in New Zealand is growing rapidly. European banned pesticides (including herbicides) in use include diquat, chlorpyrifos, dichlorvos, bifenthrin, atrazine, simazine, hexazinone, methyl bromide, sodium fluoroacetate, mancozeb, carbaryl and more… Quantities released into the environment are not documented, mixtures are common but not regulated.
Chemical regulators throughout the world face a crisis of trust. Glyphosate is the poster child of this crisis. Critical scientific papers outline how regulatory science is outdated, while not consider real world exposures. Weighting in RA is biased towards industry data selected and supplied by the manufacturers, rather than peer reviewed literature. [12] [13] The word ‘trust’ now features prominently in NZEPA annual reports, perhaps due to recognition of this problem.
Herbicides are the ‘cheap’ option when ecosystem costs are not factored into cost (or risk)-benefit scenarios. Industry applications and NZEPA decision documents reveal that NZEPA risk-benefit analyses over-emphasise industry claims. Emphasis is placed on risk to production (GDP) if herbicides are withdrawn.
Herbicide mixtures which bioaccumulate and degrade ecosystem services are not factored in as economic costs in NZEPA risk-benefit analysis. Off-target effects are not considered in cost-benefit scenarios such as detection by offshore regulatory regimes, the potential for herbicides to speed antibiotic resistance and the cost of stripping emerging contaminants out of drinking water. Instead, the major ‘risk’ that is effectively valued is based on risk to production tonnages, based on data supplied by industry.
Central to the nature of this CFI is a wish to place on the public record that there is extensive evidence of a systemic reluctance by New Zealand’s regulatory agency and associated authorities to adopt an integrated risk assessment based on a mix of toxic compounds used by categories of user ‘integrated user risks’ and categories of food which accumulate many different toxins to create an ‘integrated food-product consumer risk’.
Capable stewardship requires integration to ensure appropriate foresight, insight and oversight.[14] Economic benefit should outweigh end-points which retain trust in regulators: the safety and protection of categories of user; safety and protection of people exposed to end-products; and safety and protection of a healthy environment. These endpoints include the protection of ecosystem services and the protection of Papatūānuku –the protection of the mauri (life force) of water and the protection of drinking water.
As mixtures are the ‘norm’. Avoiding looking at mixture toxicity is unscientific. Current evidence indicates that there is a predominant regulatory focus on enabling chemical products to be used in NZ on the bases of singular substances not inclusive of toxic synergies within trade-name products; not inclusive of toxic exposures of categories of user; not inclusive of integrated total toxic loads in end-food-products; and not inclusive of accumulative and synergistic toxicity in the environment.
Endocrine disruption carries little weighting in decision-making. Unlike other jurisdictions, New Zealand lacks policy drawing attention to low level ‘sub-lethal’ risk from endocrine disrupting activities that interact at the level of the hormone. This cascades into an absence of scientific research, such as research considering cumulative herbicide exposures to users that can produce sublethal synergistic and or additive effects at environmentally relevant levels.[15] [16] [17] [18]
Regional pressures from pesticides differ. While horticulture yields more than broadacre crops, horticultural land generates on average ten times the aquatic ecotoxicity hazard and five times more human toxicity hazard than a hectare of broadacre crops [19]
Europe’s risk assessments scientifically remain far superior to risk assessment in New Zealand. While insufficiently transparent and subject to conflicts of interest[20], European assessments are more scientifically thorough and there is a line of sight between toxicity and potential for authorisation, or the decline of an application. New Zealand’s reliance on ‘cost-benefit’ is less transparent and muddled, skewing NZEPA deliberation to favour industry claims as there is no line of sight between toxicity and regulation.[21] [22] [23]
The European Environmental Agency has taken a lead in recognising escalating pollution from synthetic chemicals, and the cocktail effect of chemical mixtures.[24] This has informed the development of the Healthy Planet for All EU Action Plan[25] and the Farm to Fork Strategy which includes a reduction of pesticide use by 50%.[26] There is no integrated approach in New Zealand.
The Parliamentary Commissioner for the Environment (PCE) has remarked on the absence of local knowledge, monitoring and environmental science ‘leaving researchers to cobble together piecemeal solutions.' In particular, the PCE has recognised the absence of a clear line of sight that can lead to strategic long-term action.[27]
As the PCE has stated:

I am not confident that there is a coherent basis for our national investment in environmental science. I am particularly concerned that there is no mechanism that links the ongoing demand environmental reporting makes for an understanding of complex ecological processes that evolve over decades, and a science funding system that is constantly searching for innovation, impact and linkages to the ever-changing demands of business and society.[28]

We question if the NZEPA and Ministry for the Environment has engaged in consultation with their Treaty partners as to the increasing range of banned chemicals in our soil and water and strategies by which the substantial scientific resources harnessed in European chemical stewardship, through the EFSA and the European Chemicals Agency (ECHA), might be harnessed to protect New Zealand soil and water.
Drinking water is at risk if current standards are relied upon. For example, we wonder what the public and what Māori would think of the European Commission Drinking Water Directive 98/83/EC, which stipulates a maximum concentration of any individual pesticide in drinking water of 0.1 μg/L and maximum concentration of the total sum of all pesticides present (including metabolites) as limited to 0.5 μg/L. New Zealand has no policy for ‘aggregate toxicity’ from emerging contaminants including pesticides.
Glyphosate drinking water levels are remarkably high. New Zealand currently relies on a 1981 Monsanto Biodynamics study to establish maximum drinking water levels for glyphosate. This was set in 1985.[29] Using unpublished 20-year-old data, the World Health Organisation (WHO) claims that no formal guideline value is necessary and assert that exposures of glyphosate up to 0.9mg/L (or 900 μg/L) is safe, and maintaining that such a high level is unlikely to be detected. The Drinking Water Standards for New Zealand have adopted the WHO’s perspective. [30]
Unlike the European Commission, the WHO is not democratically accountable. The glyphosate levels, set in 1985 were set based on industry data submissions.
The European Commission has embedded a stronger application of the precautionary principle in European legislation.[31] This has enabled decisions to be undertaken when science continues to be uncertain, in the public interest. A strong application might better enable the Crown to honour Treaty of Waitangi obligations.
The HSNO Act and accompanying Methodology Order implement a weak form of precaution.[32]
A stronger application of the precautionary principle might also be recognised as a process similar to the actions of Māori to place a rāhui on an area for protective reasons. For example, a rāhui would not be placed on collection of pipi before all the pipi was harvested to extinction.
Cabinet budgeting can flip the knowledge base. There is potential for economic analyses to explore the costs of integrated strategies. These alternatives currently appear more expensive than chemical regimes as pollution in soil, marine, freshwaters and drinking water, and frequent user health is not taken into account.
Cabinet budgeting can support rapid uptake of integrated weed management and associated tech in agriculture. New technology is advancing swiftly.[33] Remote controlled mulching and mowing, high speed mechanical technologies, cover cropping and shallow tilling to manage weed seed populations. Are all components in a suite of strategies that protect soil and water.[34]
Cabinet budgeting can assist with transition of TLAs and public authorities away from intensive dependence on industrial chemical agriculture. This includes asset management in urban environments, roadside, utilities and railway tracks, and Department of Conservation work.
Organic consumers purchase organic product because it is more natural and pesticides residues and sprays are health protective, and orders of magnitude lower.[35] [36] The organics sector is growing, and key export markets include the U.S., China, Europe and Australia.[37]
Is the CFI an unnecessary step? With 6,000 chemicals to steward, the NZEPA is very busy. There are 40,000 to 60,000 industrial chemicals in commerce globally. 6,000 of these chemicals account for more than 99 per cent of the total volume. 62% of the volume of chemicals produced are hazardous to health.[38]
The CFI can be integrated into a hazard/risk assessment.
Manmade pollution is threatening humanities ‘safe operating space’.[39] Government agencies acknowledge there is a global pollution crisis, driven predominantly by the release of manmade chemicals. Major work to shift policy is being undertaken by the United Nations Environment Programme,[40] and the European Commission.[41]

AUGUST 2022 UPDATE

REFERENCES

[1] Boedeker et al 2020. The global distribution of acute unintentional pesticide poisoning: estimations based on a systematic review. BMC Public Health 20:1875

[2] Buddenhagen et al 2019. Costs and risks associated with surveying the extent of herbicide resistance in New Zealand. New Zealand Journal of Agricultural Research, DOI: 10.1080/00288233.2019.1636829

[3] New York Times. Attack of the Superweeds. https://www.nytimes.com/2021/08/18/magazine/superweeds-monsanto.html?

[4] Heap. International Herbicide Resistant Weed Database. http://www.weedscience.org/Home.aspx

[5] Silva et al 2019. Pesticide residues in European agricultural soils – A hidden reality unfolded. Science of The Total Environment. 653:1532-1545

[6] Tang & Maggi 2021. Pesticide mixtures in soil: a global outlook. Letter. Environ. Res. Lett. 16:044051

[7] Da Silva et al 2021. Pesticides in a case study on no‑tillage farming systems and surrounding forest patches in Brazil. Nature 11:9839 DOI: 10.1038/s41598-021-88779-3

[8] Raffa & Chiampo 2021. Bioremediation of Agricultural Soils Polluted with Pesticides: A Review. Bioengineering. 8:92

[9] Beckie 2021. Herbicide resistance management strategies: How do they compare with those for insecticides, fungicides and antibiotics? Perspective. DOI 10.1002/ps.6395

[10] Mode of action – the target site where a pesticide will cause physiological disruption to the target species.

[11] New Zealand Winegrower 2015. https://www.ruralnewsgroup.co.nz/wine-grower/wg-general-news/herbicide-resistance

[12] Myers et al 2016. Concerns over use of glyphosate-based herbicides and risks associated with exposures: a consensus statement. Environmental Health 15:19

[13] Robinson et al 2020. Achieving a High Level of Protection from Pesticides in Europe: Problems with the Current Risk Assessment Procedure and Solutions. European Journal of Risk Regulation. DOI:10.1017/err.2020.18

[14] Boston, J., Bagnall, D., & Barry, A. (2019). Foresight, insight and oversight: Enhancing long-term governance through better parliamentary scrutiny. Institute for Governance and Policy Studies. School of Government Victoria University of Wellington.

[15] Hasenbein et al 2015. The use of growth and behavioral endpoints to assess the effects of pesticide mixtures upon aquatic organisms. Ecotoxicology DOI 10.1007/s10646-015-1420-1

[16] Martin et al. 2021. Ten years of research on synergisms and antagonisms in chemical mixtures: A systematic review and quantitative reappraisal of mixture studies. Environment International 146:106206 doi:https://doi.org/10.1016/j.envint.2020.106206

[17] Siviter et al 2021. Agrochemicals interact synergistically to increase bee mortality. Nature 596389-392

[18] Mesnage et al 2019. Transcriptome profile analysis reflects rat liver and kidney damage following chronic ultra-low dose Roundup exposure. Environmental Health. DOI 10.1186/s12940-015-0056-1

[19] Navarro et al 2021. Pesticide Toxicity Hazard of Agriculture: Regional and Commodity Hotspots in Australia. 55:2;1290-1300 DOI: 10.1021/acs.est.0c05717

[20] Robinson et al 2020. Achieving a High Level of Protection from Pesticides in Europe: Problems with the Current Risk Assessment Procedure and Solutions. European Journal of Risk Regulation. DOI:10.1017/err.2020.18

[21] Eg. Decision discussion for Paraquat (APP203301); 600g/L glyphosate Crucial (APP203611) & Grunt (APP204109)

[22] NZEPA 2020. Risk Assessment Methodology for Hazardous Substances. https://www.epa.govt.nz/assets/Uploads/Documents/Hazardous-Substances/Risk-Assessment-methodology/Risk-Assessment-Methodology-for-Hazardous-Substances-How-to-assess-the-risk-cost-and-benefit-of-new-hazardous-substances-for-use-in-New-Zealand-v2.docx

[23] Kaltenhauser et al 2017. Relevance and reliability of experimental data in human health risk assessment of pesticides. Reg.Tox & Pharm. 88

[24] EEA. (2018). Chemicals in European Waters: Knowledge Developments. EEA Report 18/2018. European Environmental Agency.

[25] European Commission 2021. Zero pollution action plan. https://ec.europa.eu/environment/strategy/zero-pollution-action-plan_en

[26] Farm to Fork Strategy. https://ec.europa.eu/food/system/files/2020-05/f2f_action-plan_2020_strategy-info_en.pdf

[27] PCE 2020. A review of the funding and prioritisation of environmental research in New Zealand

[28] PCE 2019. Focusing Aotearoa New Zealand’s environmental reporting system. P.6

[29] WHO 2017 Guidelines for Drinking Water Quality. Fourth Edition.

[30] Ministry of Health 2018. Volume 3 Datasheets. Part 2.3. Chemical and physical determinands: Pesticides. Guidelines for Drinking-water Quality Management for New Zealand, June 2018

[31] Iorns Magallanes 2018. Permitting Poison: Pesticide Regulation in Aotearoa New Zealand. EPLJ, 456-490.

[32] Iorns Magallanes 2018. Permitting Poison: Pesticide Regulation in Aotearoa New Zealand. EPLJ, 456-490.

[33] E.g. Grazer (New Zealand) Mowing/mulching in difficult to access areas. https://www.grazer.co.nz/

E.g. Roadside, urban, agriculture. https://zasso.com/products/

E.g., Cassini Grasskiller https://www.youtube.com/watch?v=W_aTuzSqTSY

E.g., Roadside Dücker, Gerhard, GmbH & Co. KGLSM 740 guiding post mower https://www.youtube.com/watch?v=7-pXAv0W2-I&t=54s

Eg. Urban Foamstream. https://www.youtube.com/watch?v=KD7B658U_gU

[34] E.g., Merfield 2019. Integrated weed management in arable crop systems. Foundation for Arable Research.

[35] Benbrook et al 2021. Organic Farming Lessens Reliance on Pesticides and Promotes Public Health by Lowering Dietary Risks. Agronomy 2021, 11, 1266. https://doi.org/10.3390/agronomy11071266

[36] Geissen 2021. Cocktails of pesticide residues in conventional and organic farming systems in Europe Legacy of the past and turning point for the future. Environmental Pollution 278: 116827

[37] Organics Aotearoa New Zealand. 2020/21 Time for Action. New Zealand Organic Sector Market Report.

[38] United Nations Environment Programme, 2019. Global Chemicals Outlook II From Legacies to Innovative Solution

[39] Steffen (2015) Planetary boundaries: Guiding human development on a changing planet. Science

[40] United Nations Environment Programme, 2019. Global Chemicals Outlook II From Legacies to Innovative Solution

[41] European Commission 2021. Pathway to a Healthy Planet for All EU Action Plan: 'Towards Zero Pollution for Air, Water and Soil

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