SUBMISSION ON APP202170 – Application to import CADET herbicide . from TE RŪNANGA O NGĀI TAHU by Dr Oliver Sutherland presentation by Gerry Te Kapa Coates Member, HSNO komiti
THE NGĀI TAHU TAKIWĀ Over 90% of the South Island & over 40% of NZ land mass. • Ngāi Tahu is the third largest Māori tribe in Aotearoa with over 54,000 members. • Our takiw ā extends from Kaikoura in the north, to Rakiura (Stewart Island) in the south, including the West Coast, TeTai Poutini. • Te Rūnanga o Ngāi Tahu constitutes 18 Rūnanga representing geographical areas, generally based around traditional settlements. “Te Puna Waimaraarie, Te Puna Hauaitu, Te Puna Karikari ” The pools of frozen water; The pools of bounty; The pools dug by the hand of humans ” - Rakaihautu Slide 2
Our takiw ā Kia tuohu koutou, Me he mauka teitei, Ko Aoraki anake. “If you must bow your head then let it be to the lofty mountain Aoraki” Slide 3
TE RŪNANGA O NGĀI TAHU HSNO KOMITI • 7 Members • Responsible for monitoring new EPA applications • By HSNO Policy Statement 2008
THE POLICY a) Evaluate issues of importance to Ngāi Tahu b) Identify and assess effects (risks and benefits), from a Ngāi Tahu perspective c) Identify options to avoid or minimise adverse effects on Ngāi Tahu values d) Identify outcomes important to Ngāi Tahu (e.g. environmental, cultural, health and well-being, economic). Ngāi Tahu have a unique body of knowledge and practice relating to the environment and the relationship of people to the environment. This knowledge and practice can complement scientific knowledge, and provide better understandings of the effects of hazardous substances and new organisms on the environment and our communities.
ISSUES CONSIDERED • Lack of culturally relevant information in applications. • Difficulties of assessing highly technical applications . • Time and cost burden to Te Rūnanga o Ngāi Tahu of assessing applications, particularly when applicants provide insufficient information on issues of cultural importance • Pollution of the natural environment from the storage, use and disposal of hazardous substances. • Potential effects on native species (positive and adverse) from the use and disposal of hazardous substances. • Risk to human health , posed by the storage, use or disposal of hazardous substances, directly or indirectly (e.g. bioaccumulation in mahinga kai species and subsequent human consumption). • Cultural and environmental effects of transport of hazardous substances. • Long term effects of hazardous substance use. • Risks of emergencies or accidents from the manufacture, use, disposal and transport of hazardous substances . • How are cultural and Treaty concerns reflected in EPA decisions on applications
TREATY CONSIDERATIONS • Te Rūnanga o Ngāi Tahu was statutorily recognised as the representative tribal body of Ngāi Tahu Whānui under section 6 of Te Rūnanga o Ngāi Tahu Act 1996. • This means we exercise kaitiakitanga over our takiw ā . • The EPA must be ever mindful of its responsibilities for ‘active protection’ under Te Tiriti o Waitangi. • Active protection needs to operate in terms of Te Tiriti , not through general concerns about health and safety issues and mechanisms. • The EPA’s role must also include requiring testing and research to be carried out on impacts of hazardous substances on 'down- stream' taonga native species and ecosystems , in a similar manner to that required for introduced bio-controls. The lack of , or access to any testing or research data is a major shortcoming in most Applications.
SUBMISSION ON APP202170 – Importation of Cadet herbicide We oppose the introduction of Cadet, an emulsifiable substance containing fluthiacet-methyl as the active ingredient for the following reasons: • Cadet is not intended to be used alone, but with several other per-emergence herbicides meaning that each mix is effectively a different, new and untested and unregistered herbicide. • This is not mentioned as part of the Application itself or the accompanying Material Safety Data Sheet. The Application Form requires details to be provided not only on the active ingredients but also on ‘the mixture’ and this has not been done.
SUBMISSION ON APP202170 – cont. 1 • The inclusion of key data on composition and toxicology in confidential files does not enable submitters to fully assess the application. • Almost 90% of Cadet comprises three compounds other than the active ingredient which include acetophenone (40- 50%), methyl pyrollidone (20-30%) and naptha (10-20%). Naptha alone is toxic to freshwater fish. The complete list of ingredients needed to have been in the Application Form. • The environmental fate of the Cadet mixture alone is unclear from the jumble of figures and bland statements provided. The applicant should have provided toxicological and ecotoxicological on Cadet as a whole in the mixture form it will be applied.
SUBMISSION ON APP202170 – cont. 3 • Neither the completed Application form nor the MSDS disclose that Cadet will not be used alone although material circulated to Te Herenga but not associated with the Application on the EPA website states that the intended use is ‘in mixture’ with other herbicides . • Cadet is effectively nothing more than one component of one, two, three or more new herbicides, e.g. Cadet plus atrazine et al. • The information on risks, costs and benefits is sketchy and contradictory with little or no data to sustain the claims made. Getting no response from M ā ori does not mean that ‘any effects are unlikely to be significant to the outcomes of importance to Māori’. Ngāi Tahu are deeply concerned.
SUBMISSION ON APP202170 – cont. 4 International concerns on assessing the risks of mixtures Society of Environmental Toxicology and Chemistry Risk Assessments of Dissimilar Mixtures Posted By Mark Richardson (SNC. LAVALIN) , Tuesday, April 03, 2012 The toxicity of constituents is not always independent when they are present in mixtures. The scientific literature has an increasing assortment of research articles concerning the interactive toxicological effects of chemicals. Increasingly, agencies such as the EPA and ATSDR are formulating guidance on how to assess mixtures. http://www.setac.org/blogpost/784751/141079/Risk-Assessments-of- Dissimilar-Mixtures
SUMMARY We request the Application be rejected without further consideration because: • The Application is not relevant to the intended use pattern for the product. • No ecotoxicological data has been provided for the mixtures and their environmental fates that may arise from the proposed use patterns. • No persuasive case for risks and benefits has been made. “There are some choices you can only make once. You can't go back to where you made a choice and then take the other one.” ― Mary Hofffman
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